Eleventh Circuit Court of Appeals - Published Opinions

Monday, August 14, 2006

Hallford: Brady violation not prejudicial

In Hallford v. Culliver, No. 05-12621 (Aug. 11, 2006), the Court affirmed the denial of habeas relief to an Alabama inmate sentenced to death for a 1986 murder.
Hallford claimed that a Brady violation occurred when the State failed to disclose a plea agreement with the victim’s daughter, who was the lead witness against him. The Court recognized that such evidence can be material, but here its withholding was not sufficiently prejudicial to the defendant, in light of the other overwhelming evidence against him.
The Court also rejected an ineffective assistance of counsel claim. The Court found that it was not ineffective for counsel to open the door to evidence that the defendant had committed incest with his daughter who testified against him, as attacks on the daughter’s credibility were a logical part of the guilty phase of the case.