Willie James Pye v. Warden, Georgia Diagnostic Prison, No. 18-12147 (11th Cir. 2022)
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Petitioner was convicted by a Georgia jury of kidnapping, robbery, gang rape, and murder. The jury recommended that Petitioner be sentenced to death for his crimes. Having exhausted his state post-conviction remedies, Petitioner filed a federal habeas corpus petition, arguing, as relevant here, that his trial counsel rendered him constitutionally ineffective assistance in connection with the sentencing phase of his trial. The district court denied relief, but a panel of the Eleventh Circuit reversed and vacated Petitioner’s death sentence, holding that the state court’s rejection of his ineffective-assistance-of-counsel claim was based on an unreasonable determination of the facts and involved an unreasonable application of clearly established federal law.
The Eleventh Circuit granted rehearing en banc to decide whether the state court’s decision that Petitioner is not entitled to relief on his ineffective assistance claim warrants deference under the Antiterrorism and Effective Death Penalty Act (AEDPA). The court affirmed the district court’s denial of Petitioner’s petition and remanded it to the panel. The court held that the state court reasonably concluded that Petitioner was not prejudiced by any of his counsel’s alleged deficiencies in connection with his sentencing proceeding.
The court explained that while Petitioner argues that the background evidence that Mostiler should have presented parallels the evidence in Williams v. Taylor, 529 U.S. 362 (2000), and Rompilla v. Beard, 545 U.S. 374 (2005), those cases “offer no guidance with respect to whether a state court has unreasonably determined that prejudice is lacking” because the Supreme Court “did not apply AEDPA deference to the question of prejudice in those cases.”
This opinion or order relates to an opinion or order originally issued on September 1, 2021.
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