Eleventh Circuit Court of Appeals - Published Opinions

Wednesday, May 18, 2016

Daniel: Reversing denial of ineffective claim

In Daniel v. Commissioner, Ala. Dep’t of Corrections, No. 14-12558 (May 16, 2016), the Court reversed the denial of habeas relief to an Alabama inmate sentenced to death for 2001 murders. The Court found that at the penalty phase of Daniel’s Alabama trial, counsel was ineffective in failing to conduct meaningful mitigation investigations into Daniel’s cognitive impairments, or to investigate the nature of Daniel’s prior conviction. The Court found that the Alabama Court of Criminal Appeals adjudication of these issues was contrary to or an unreasonable application of clearly established federal law. Daniel’s claim was therefore reviewable de novo. The Court remanded the case to the district court to reconsider Daniel’s discovery motion regarding his former lawyer’s records, for an evidentiary hearing, and to consider Daniel’s ineffectiveness claim de novo.