Williams v. Superintendent Mahanoy SCI, No. 20-2999 (3d Cir. 2022)
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Granthon was shot dead on a Harrisburg, Pennsylvania street corner. A day earlier, Granton had purchased an ounce of crack cocaine from Burton. Granthon “was short a couple grams” and sought a refund. The evidence linking Burton to Granthon’s death was “overwhelming.” Burton was convicted of first-degree murder. Williams was also charged with first-degree murder, conspiracy, and reckless endangerment of another but the evidence was weaker. No witness recognized Williams and no cell phone records placed him near the scene that night. Williams claimed he spent the night at a casino, but offered conflicting alibi stories and never used his casino rewards card that night. Williams’s trial lawyer’s “defense theory” was that Williams was “not placed at the scene.” He did not call Rochon, a witness at Burton’s trial whose testimony allegedly indicated that Granthon also shot a gun, nor did he make the case for self-defense or voluntary manslaughter.
Williams was convicted and sentenced to life in prison. The Third Circuit affirmed the denial of his petition for habeas relief, rejecting claims of ineffective assistance of counsel. His trial attorney’s alleged negligence is not self-evident, as the attorney may have reasonably thought that self-defense arguments would detract from an alibi defense. To show his attorney was negligent, Williams would need to develop the record in district court but the Antiterrorism and Effective Death Penalty Act forbids federal courts from supplementing the state court record under these circumstances.
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