Carl Puiatti was convicted in Florida of kidnapping, robbery, and murdering Sharilyn Ritchie and received a death sentence. In federal habeas proceedings, he argued that penalty-phase counsel performed deficiently by failing to uncover and present additional evidence of childhood abuse and related family dysfunction. The district court held an evidentiary hearing and denied relief. The Eleventh Circuit affirmed. The court assumed that some of the newly developed abuse evidence could have been mitigating, but held that Puiatti could not show a reasonable probability of a different sentence under Strickland. Counsel had investigated Puiatti’s background, consulted a psychiatrist and psychologist, presented evidence of his dependent personality, learning disability, drug use, family relationships, and potential for rehabilitation, and argued those circumstances to the jury and sentencing judge. The proposed new evidence was comparatively weak against three powerful aggravating circumstances, including a cold, calculated, and premeditated killing. Presenting it also would have opened the door to damaging evidence of other violent and antisocial conduct. Because the additional evidence would not have overcome the aggravation or changed the sentencing balance, the court affirmed denial of the § 2254 petition. Judge Martin specially concurred only in the result.