John R. Wood v. Bryan Stirling, Commissioner, South Carolina Department of Corrections, et al.
HabeasCorpus
Whether the state court unreasonably applied Strickland-v-Washington
QUESTION PRESENTED At the penalty phase of Petitioner’s capital trial, the crux of the State’s case for death rested on “prison conditions” evidence from a single Department of Corrections employee who suggested that due to the many amenities and privileges provided to inmates, sentencing Petitioner to life in prison would have little retributive value. Trial counsel raised no objection. Based on this evidence, the State argued that jurors should sentence Petitioner to death because “putting him in prison isn’t going to make him suffer,” “[g]oing to prison is like being in a big city,” and “prison is just about going to be a change of address and nothing more.” Again, trial counsel did not object. It is undisputed that prison conditions evidence was inadmissible as a matter of South Carolina law. Despite the State’s heavy reliance on this inadmissible evidence, and a powerful (and improper) closing argument crafted upon it, Petitioner’s jury was deadlocked and struggled over the course of three days before reaching a unanimous verdict for death. The state postconviction relief (PCR) court found (and the State conceded below) that Petitioner’s counsel performed deficiently by failing to object to the prison conditions evidence, but the PCR court concluded there was no prejudice. The Fourth Circuit Court of Appeals sanctioned this outcome by inventing reasons to justify the state court’s decision that were never discussed or endorsed by the state court, contrary to this Court’s instruction that when a state court gives a reasoned explanation for its decision, “a federal habeas court simply reviews the specific reasons given by the state court and defers to those reasons if they are reasonable.” Wilson v. Sellers, 138 S. Ct. 1188, 1192 (2018). The questions presented are: 1. Whether the state court unreasonably applied Strickland v. Washington, 466 U.S. 668 (1984), when it concluded that Petitioner suffered no prejudice because the defense had “fully joined” the prison conditions issue by presenting evidence to show that Petitioner was adaptable to confinement? 2. Whether the Fourth Circuit’s § 2254(d)(1) analysis, which is based on factually unsupported reasons not found in the state court decision, contravenes this Court’s decision in Wilson v. Sellers, supra? i