In Suggs v. McNeil, No. 09-12718 (June 24, 2010), the Court affirmed the denial of habeas relief to a Florida inmate sentenced to death for a 1990 murder.
The Court rejected the argument that the Florida Supreme Court unreasonably applied the prejudice prong of Strickland when it determined that counsel’s failure at the penalty phase to adequately present a defense based on Suggs’ mental health did not prejudice the outcome.
The Court rejected the argument that the Florida courts were not entitled to deference because they compartmentalized the different aspects of prejudice. The Court noted that the Florida Supreme Court stated that it had considered the penalty phase “as a whole.”
The Court recognized that the jury had split 7-5 in favor of death, but found that Suggs had not shown that new evidence of his mental deficit, along with new aggravating evidence, would not have caused a single new juror to vote for life and no new jurors to vote for death. Even in light of the closely divided jury, the evidence of Suggs’ mental deficit would not have changed the outcome, because of he fell “well within the normal range of general intellectual functioning,” and additional evidence of mental history would have opened the door for the State to present evidence of Suggs’ drug and alcohol use. Further, the State would have been able to paint Suggs as a violent, manipulative person.
