Miller v. Anderson
2000 WL 33406984, 2000 U.S. Dist. LEXIS 21581, 162 F.Supp.2d 1057 (2000)
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Rule of Law:
Under the Antiterrorism and Effective Death Penalty Act (AEDPA), a federal court may only grant habeas corpus relief for an ineffective assistance of counsel claim if the state court's adjudication was contrary to, or involved an unreasonable application of, the standard established in Strickland v. Washington. A state court's application of Strickland is not unreasonable simply because the federal court would have reached a different conclusion; it must be objectively unreasonable.
Facts:
- On November 12, 1990, Perry Steven Miller suggested to his wife's son, William Hannon, and Hannon's friend, Rodney Wood, that they rob the White Hen Pantry convenience store.
- The following evening, Miller again discussed the robbery with Hannon and Wood, adding that they should kidnap, rape, and murder the clerk, Christel Helmchen.
- Around midnight on November 13, Miller drove Hannon and Wood to a construction site to show them where to bring Helmchen, then dropped them off at the White Hen Pantry.
- Hannon and Wood robbed the store, abducted Helmchen in her car, and took her to the designated construction site.
- Miller followed in his own car and, upon arriving at the site, participated with Hannon and Wood in the sexual assault, torture, and brutalization of Helmchen.
- Following Miller's instructions, Hannon shot Helmchen in the back of the head with a shotgun, killing her.
- The next day, Helmchen's checkbook was found in the driveway of Miller's residence.
- After being arrested in Kentucky, Hannon and Wood gave statements to the police implicating Miller as the instigator and a participant in the crimes.
Procedural Posture:
- Perry Steven Miller was convicted of murder by a jury in an Indiana state trial court, which recommended a death sentence.
- The trial court judge sentenced Miller to death.
- Miller appealed his conviction and sentence directly to the Indiana Supreme Court, which affirmed the trial court's judgment.
- Miller then filed a petition for post-conviction relief (PCR) in the state trial court, alleging, among other things, ineffective assistance of his trial and appellate counsel.
- After an evidentiary hearing, the PCR court denied Miller's petition.
- Miller appealed the denial of post-conviction relief to the Indiana Supreme Court, which affirmed the PCR court's decision.
- The Supreme Court of the United States denied Miller's petition for a writ of certiorari.
- Miller filed a petition for a writ of habeas corpus in the U.S. District Court for the Northern District of Indiana.
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Issue:
Does a state court's determination that trial and appellate counsel's performance was not deficient under Strickland v. Washington constitute an unreasonable application of clearly established federal law, thereby warranting federal habeas corpus relief?
Opinions:
Majority - Judge Allen Sharp
No. The state court's determination that Miller's counsel was not ineffective did not involve an unreasonable application of the Strickland standard, and therefore federal habeas relief is not warranted. The court must apply a highly deferential standard of review under AEDPA, which requires evaluating whether the state court's application of clearly established federal law was objectively unreasonable, not merely incorrect. The Indiana Supreme Court correctly identified Strickland v. Washington as the governing legal principle for ineffective assistance of counsel claims. In reviewing Miller's specific claims—such as counsel's handling of hair and DNA evidence, failure to impeach a witness more thoroughly, and strategic decision to introduce character evidence that opened the door to damaging rebuttal—the state court's conclusions that counsel's actions were either reasonable trial tactics or not prejudicial were not an unreasonable application of Strickland. Strategic choices made after a thorough investigation of law and facts are virtually unchallengeable, and even poor strategic decisions made in hindsight do not necessarily amount to constitutionally deficient performance. Since the state court's analysis of both the performance and prejudice prongs of Strickland was reasonable, this federal court cannot grant the writ of habeas corpus.
Analysis:
This case serves as a powerful illustration of the high threshold for obtaining federal habeas relief under AEDPA, particularly for ineffective assistance of counsel (IAC) claims. The court's analysis demonstrates that federal review of a state court's Strickland adjudication is not a de novo reassessment of counsel's performance. Instead, the focus is on the reasonableness of the state court's decision-making process. The opinion reinforces the significant deference given to counsel's strategic decisions and solidifies the principle that a state court's ruling must be 'objectively unreasonable,' not just wrong, to be overturned, thereby emphasizing the finality of state criminal convictions.
