Sumnar Brewster was convicted of armed robbery after a jury repeatedly reported that it could not reach a unanimous verdict. Over two days, the jury sent six notes describing deadlock, including an eleven-to-one split. The trial judges repeatedly instructed the jurors to continue deliberating, gave an Allen charge, and ultimately ordered the removal of reading materials from the jury room after learning that the holdout juror was doing crossword puzzles. The jury returned a guilty verdict eighteen minutes later. Brewster’s attorneys never objected or moved for a mistrial. In a federal habeas petition, he claimed ineffective assistance for failing to challenge the coercive deliberations. The Eleventh Circuit held that the state court had not adequately applied the governing constitutional standard and remanded for further proceedings. The court emphasized that a jury may be encouraged to deliberate, but instructions and courtroom conduct cannot coerce a verdict or undermine an individual juror’s honest judgment. The repeated deadlock reports, pressure to continue, and abrupt verdict after the reading materials were removed required a legally adequate review of counsel’s performance and resulting prejudice.