Whether an appellate court's de novo review of a trial court's Strickland prejudice determination can disregard the trial court's express factual findings about the prejudicial effect of improperly admitted collateral crime evidence

No question identified. : 2. This case involves important questions of federal statutory and constitutional law. Mr. Woodruff brought an claim under Strickland v. Washington, 466 U.S. 668 (1984) in the same state court that presided over his criminal trial. After conducting an evidentiary hearing, the trial court granted him a new trial after finding his attorney’s failure to object to the introduction of uncharged crimes prejudiced Mr. Woodruff’s defense. 3. The state appellate court overturned that decision. State v. Woodruff, 346 So. 3d 1238 (Fla. 3d DCA 2022). While it recognized that Florida law ordinarily presumes that the erroneous admission of collateral crime evidence constitutes harmful error, it declined to apply that rule to determinations involving Strickland prejudice. It also ruled that Strickland prejudice is a “question of law” that must be reviewed “de novo,” in spite of the trial court’s express findings that the “sheer number” of allegations of uncharged crimes against Mr. Woodruff was “extremely prejudicial” and likely convinced the jury that he was a “bad person” and so alleged “misconduct must have occurred.” In reversing the trial court, the appellate court reasoned that the jury acquitted Mr. Woodruff on three counts but convicted him on the remaining count, which indicated that there was “no reasonable probability that counsel’s failure to object to the admission of the improper [collateral crime] evidence affected the outcome” of his trial. 4, In his federal habeas petition, Mr. Woodruff asserted that the state appellate decision was objectively unreasonable in that it misstated the legal standard for prejudice under Strickland, which calls for a fact-intensive review of the “totality of the evidence,” erroneously failed to afford any deference to the factual findings of the court that was in the best position to gauge the prejudicial effect on the trial, and “interpreted” the meaning of the jury’s verdict to conclude that there was no prejudice, in contravention of United States v. Powell, 469 U.S. 57, 62-66 (1984). The district court rejected those arguments. The Eleventh Circuit denied Mr. Woodruffs request for a certificate of appealability in which he renewed them. 5. The federal statutory and constitutional issues involved include but are not limited to: whether it is reasonable for an appellate court reviewing a trial court decision finding a defendant suffered Stickland prejudice to disregard express factual findings made in support of the prejudice determination; whether an applicant for a certificate of appealability has “made a substantial showing of the denial of a constitutional right,” 28 USS.C. § 2253(c)(2), where two tribunals—the court that presided over the trial and the appellate court reviewing that court’s decision—reached differing conclusions regarding Strickland prejudice; and whether a state appellate court may look to a general verdict to predict whether there is a reasonable likelihood that the outcome would have been different, but for the deficient performance of a trial attorney. 6. Applicant’s counsel, Andrew B. Greenlee, was not the attorney of record in the United States Court of Appeals for the Eleventh Circuit and was only recently retained. As such, counsel needs additional time to review the entire record, which includes transcripts from a jury trial and an evidentiary hearing, and fully brief the issues to be presented to this Honorable Court. 7. Moreover, Applicant’s counsel has other substantial obligations between now and the current deadline, including the preparation of two petitions for writs of certiorari for submission in this Court, Christin Bilotti v. Florida Department of Corrections, Case No. 23-11759 (11th Cir. 2025) (petition for writ of certiorari due on October 15, 2025); Damion Anthony Delapena v. Florida Department of Corrections, Case No. 25-10964 (11th Cir. 2025) (petition for writ of certiorari due on October 27), as well as oral argument