Bryant v. Brown, No. 15-3144 (7th Cir. 2017)Annotate this Case
Bryant was convicted of murdering his stepmother. He was 17 years old at the time of the 2000 killing. Under Indiana law juveniles in police custody have a statutory right to “meaningful consultation” with a parent before waiving their constitutional rights. Bryant met with his mother and made an incriminating statement to her. Detectives surreptitiously recorded their conversation; the incriminating statement was introduced at Bryant’s trial through the testimony of both eavesdropping officers. Bryant’s counsel’s objection to the first officer’s testimony was overruled. On appeal, the state court held that the statement should not have been admitted, but because Bryant’s counsel did not object to the second detective’s testimony about the same statement, the error was unpreserved and effectively harmless. On state postconviction review, Bryant unsuccessfully raised a “Strickland” claim of ineffective assistance of counsel and a Brady violation claim stemming from a falsehood in a police report. Bryant then sought federal habeas relief under 28 U.S.C. 2254. The Seventh Circuit affirmed the denial of relief. The state appellate court reasonably applied Strickland and Brady, finding no reasonable probability of a different outcome, because any errors were ultimately harmless and the evidence of Bryant’s guilt was plentiful.