The Atlanta Gleaner.

Legal News

Edited By George Washington

(Testing in progress)

George Washington Statue at Federal Hall

Broadnaxv.Commissioner, Alabama Department of Corrections

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.20-12600
DecidedMay 7, 2021
Reporter996 F.3d 1215 (11th Cir. 2021)
JudgesCharles R. Wilson, Beverly B. Martin, and Jill A. Pryor, Circuit Judges
Tags
CriminalPost-Conviction ReliefHabeas CorpusIneffective Assistance of CounselHearsayDue ProcessDeath PenaltyDissent
Case Summary

Donald Broadnax, an Alabama death-row prisoner, sought federal habeas relief from convictions and a death sentence for the murders of his wife and her three-year-old grandson. On appeal, he argued that trial counsel failed to investigate an alibi, that Alabama excluded hearsay evidence at his state postconviction hearing in violation of due process, and that the prosecutor shifted the burden of proof. The Eleventh Circuit affirmed the denial of his § 2254 petition. Applying the deferential federal habeas standard, the majority concluded that the state courts rejected the alibi ineffective-assistance claim reasonably and that Broadnax had not shown the required prejudice. It likewise rejected his evidentiary and prosecutorial-misconduct claims. In a concurrence joined by Judge Jill Pryor, Judge Martin criticized the state postconviction court for excluding expert hearsay and restricting evidence of his abusive childhood, poverty, mental health, and other mitigating circumstances; she agreed that federal habeas review did not permit relief. The judgment was affirmed.

Opinion

Loading published copy…

The Far Side