Anderson v. Kelley, No. 17-2456 (8th Cir. 2019)Annotate this Case
The Eighth Circuit affirmed the district court's denial of plaintiff's petition for habeas corpus relief. The court held that plaintiff's counsel's representation did not fall below an objective standard of reasonableness, and even if it did, plaintiff has not demonstrated that he was prejudiced. The court also held that, even assuming that plaintiff fairly presented his claim to the state court, his claim failed where considering an aggravating factor in violation of a state statute alone does not amount to a constitutional violation meriting federal habeas relief. Finally, the court held that the tools were available to plaintiff to make his arguments -- that his youth at the time of the offense and the serious mental illnesses categorically exempt him from the death penalty -- before the state court, he failed to show cause, and his procedural default was not excused.