Broadnaxv.Commissioner, Alabama Department of Corrections
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.
Loading published copy…

