Eleventh Circuit Denies Habeas Relief for Murderer Sentenced to Death

In Wright v. Secretary, Florida Department of Corrections, No. 13-11832 (Aug. 4, 2014), the Eleventh Circuit affirmed the district court’s denial of Joel Dale Wright’s 28 U.S.C. § 2254 petition for a writ of habeas corpus. Before the Eleventh Circuit were three of Wright’s denied § 2254 claims, for which the district court granted certificates of appealability.

In 1983, Wright received the death penalty in connection with the sexual battery and first-degree murder of his neighbor Lima Paige Smith, a seventy-five-year-old schoolteacher. Wright intended to rob Ms. Smith’s house. Upon discovering that Ms. Smith was in fact home, Wright murdered her to avoid returning to jail for burglary. After beating Ms. Smith in the head and face and brutally raping her, Wright stabbed her neck and face twelve times. Ms. Smith eventually died by drowning in her own blood.

The Eleventh Circuit determined that the state court did not act contrary to federal law as set forth by the Supreme Court, nor did it make unreasonable determinations of the facts based on the evidence presented, in denying habeas relief. Therefore, Wright did not meet the strict standard of federal review of state denials of habeas relief under 28 U.S.C. § 2254(d) for any of his three § 2254 claims.

First, the Eleventh Circuit held that the prosecution did not withhold unknown evidence from Wright and therefore did not violate his right to due process under Brady v. Maryland, 373 U.S. 83 (1963). Wright had equal access to the evidence, thus negating any disclosure obligation of the prosecution. Nor did Wright incur any prejudice since the evidence was not favorable to him. The state court found that no Brady violations occurred, and the Eleventh Circuit held that those findings were supported by the evidence and were not contrary to federal law.

Wright complained that the prosecution withheld information concerning a state witness’ immunity agreement as to an unrelated theft of scrap metal. However, no immunity was ever granted with regard to this crime, and, therefore, there was no material that could be withheld in violation of Brady. Analogizing to Mills v. Singletary, 63 F.3d 999 (11th Cir. 1999), the Eleventh Circuit held that the prosecutor’s notes regarding what that witness would say during direct examination was merely a list of the witness’ own statements. It was therefore not a script. The prosecution was under no obligation to disclose this non-Brady material to the defense. Finally, statements implicating two possible alternative suspects were actually known to the defense without disclosure by the prosecution. Additionally, nothing in those statements exonerated Wright of guilt or affirmatively connected the possible suspects with the crime.

Second, the Eleventh Circuit applied the standard set forth in Strickland v. Washington, 466 U.S. 668, (1984) in holding that Wright’s ineffective-counsel claim did not warrant habeas relief. Wright complained that his attorney failed to call a witness that would explain that a “glass vase” of change in Wright’s possession was a family heirloom, not the “glass jar” of money stolen from Ms. Smith. However, since Wright could not show any resulting prejudice, the Eleventh Circuit did not have to reach the issue of deficiency.

Finally, Wright argued that the Florida Supreme Court, after it reversed the trial court’s finding on one statutory aggravating circumstance at the sentencing phase, failed to reweigh the remaining three statutory aggravating circumstances or make a harmless error calculation in violation of Sochor v. Florida, 504 U.S. 527 (1992). Since Sochor was decided seven years after the original appeal to the Florida Supreme Court, and since the Florida Supreme Court did conduct a harmless error analysis in 2003 in reference to his 2002 petition for a writ of habeas corpus to that court, this claim also failed.

Twitter Digg Delicious Stumbleupon Technorati Facebook Email