Bryant v. Stephan, No. 20-4 (4th Cir. 2021)
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Petitioner was convicted of first-degree murder and armed robbery, and sentenced to death for the murder and 20 years' imprisonment for the robbery. After exhausting his state remedies, petitioner sought habeas relief under 28 U.S.C. 2254. The district court vacated petitioner's death sentence, concluding that the state postconviction court (1) unreasonably determined that a juror who was hearing impaired was competent to sit on the jury and unreasonably applied clearly established federal law in so concluding; and (2) unreasonably concluded that petitioner's state trial counsel was not ineffective in allowing the hearing-impaired juror to sit on the jury. However, the district court rejected a claim by petitioner that his trial counsel was ineffective for failing to press a Batson challenge.
The Fourth Circuit reversed the district court's rulings on petitioner's claims relating to the hearing-impaired juror, concluding that the postconviction court did not unreasonably apply federal law in determining that the juror's presence on the jury did not violate petitioner's right to a competent jury. In this case, the postconviction court found that the juror heard all testimony during the guilty phase and was able to compensate for her hearing deficiencies. Furthermore, there was not a sufficient showing that the juror missed material testimony at trial or that her hearing difficulty was of such degree as to indicate she missed material testimony. Furthermore, the state postconviction court's denial of petitioner's related ineffectiveness claim was not unreasonable. Finally, the court concluded that petitioner failed to satisfy the requirement of Martinez v. Ryan, 566 U.S. 1, 17 (2012), that his underlying Batson-based claim of ineffective assistance was sufficiently substantial to allow the district court to excuse his procedural default of that claim. Accordingly, the court reversed the district court's rulings on petitioner's claims relating to the hearing-impaired juror and otherwise affirmed. The court remanded with instructions to deny petitioner's application for habeas relief under section 2254 with prejudice.
The court issued a subsequent related opinion or order on July 1, 2021.
The court issued a subsequent related opinion or order on November 15, 2021.
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