Brad Sigmon v. Bryan Stirling

Summary

Capital habeas case affirming denial of §2254 relief for South Carolina death row inmate Brad Sigmon. The Fourth Circuit held that state PCR court's rejection of ineffective assistance claims (including failure to object to prison conditions evidence, improper closing arguments, and mitigation instructions) was not an unreasonable application of Strickland under AEDPA deference. The court also found procedurally defaulted Martinez claims—failure to present additional mitigation evidence, failure to object to stun belt, and misunderstanding closing argument order—were not "substantial" because proffered evidence was cumulative and petitioner failed to show prejudice. Key holdings: state post-conviction due process claims are not cognizable on federal habeas; stun belt prejudice requires showing jurors actually saw the device; and trial counsel's ignorance of state law regarding closing argument order still failed prejudice prong.

Questions Presented

1. Whether trial counsel rendered ineffective assistance by failing to object to prison conditions evidence and closing argument (Ground 1).
2. Whether the Supreme Court of South Carolina violated Sigmon's due process and equal protection rights by denying relief to him while granting it to other inmates (Ground 2).
3. Whether trial counsel was ineffective for failing to object to portions of the prosecutor's closing argument (Ground 3).
4. Whether trial counsel was ineffective for failing to request a mitigating instruction on intoxication (Ground 4).
5. Whether trial counsel was ineffective for failing to object to the trial court's characterization of non-statutory mitigating circumstances in jury instructions (Ground 5).
6. Whether trial counsel was ineffective for pursuing an instruction on provocation by the victim (Ground 6).
7. Whether trial counsel was ineffective for failing to discover and present additional mitigating evidence (Ground 7, Martinez claim).
8. Whether trial counsel was ineffective for failing to object to the stun belt worn during trial (Ground 8, Martinez claim).
9. Whether trial counsel was ineffective for not knowing that each defense attorney could present a closing argument at sentencing (Ground 9, Martinez claim).