Summary
The Sixth Circuit affirmed the denial of Scott Allen DeBruyn’s federal habeas petition challenging his Michigan conviction for delivering oxycodone causing death. The court held that DeBruyn failed to satisfy the Antiterrorism and Effective Death Penalty Act’s deferential standard of review on his ineffective-assistance claims concerning investigation of an acetaminophen-based defense and failure to call a defense expert. The court also rejected his constitutional challenge to AEDPA’s standard of review.
Topics
Practice areas
Questions Presented
- Whether AEDPA's limitation on federal habeas relief for state prisoners violates Article III by transferring federal judicial power to state courts.
- Whether the Michigan courts unreasonably applied Strickland or unreasonably determined the facts in rejecting DeBruyn's claim that trial counsel was ineffective for failing to investigate an acetaminophen-based defense.
- Whether the Michigan courts unreasonably applied Strickland or unreasonably determined the facts in rejecting DeBruyn's claim that trial counsel was ineffective for failing to call a defense expert concerning the cause of death.
Holdings
- AEDPA's limitation on federal habeas relief for state prisoners does not transfer federal judicial power to state courts and does not violate Article III.
- DeBruyn was not entitled to habeas relief because the Michigan courts reasonably concluded that counsel's decision not to investigate an acetaminophen-based defense was a reasonable strategic choice and that the alleged omission caused no prejudice.
- DeBruyn was not entitled to habeas relief because the Michigan courts reasonably concluded that counsel could competently present the defense through cross-examination of the prosecution's experts and that the proposed expert testimony would not probably have changed the verdict.
Key quotations
“Article III does not prevent Congress from restricting the availability of the federal writ of habeas corpus to state prisoners.” (8)
“Strickland does not require counsel to investigate every conceivable defense.” (10)
“Defense lawyers do not perform incompetently by choosing to train their efforts on a reasonable defense challenging a necessary premise of the prosecution’s case.” (12)
“In the end, so long as counsel did not take “an approach that no competent lawyer would have chosen,” her decision not to hire an expert is reasonable.” (16-17)
“We affirm the district court’s judgment and deny the writ of habeas corpus.” (23)
Factual background
Scott Allen DeBruyn supplied oxycodone and other substances to Camille Gesiakowski, who had recently been released from jail and later died from a mixed-drug overdose in a hotel room with DeBruyn. The prosecution presented evidence that DeBruyn repeatedly promised to obtain oxycodone for Gesiakowski, purchased Percocet shortly before her death, and that oxycodone was a substantial factor in the death. DeBruyn's trial counsel challenged causation through cross-examination of the State's experts but did not investigate an acetaminophen-based defense or call a defense expert.
Procedural history
A Michigan jury convicted DeBruyn of delivering a controlled substance causing death. After the Michigan Court of Appeals granted a Ginther hearing, DeBruyn moved for a new trial based on counsel's failure to investigate an acetaminophen-based defense and failure to call a defense expert. The trial court rejected the claims, the Michigan Court of Appeals affirmed, and the Michigan Supreme Court denied leave to appeal. The federal district court denied DeBruyn's habeas petition, and the Sixth Circuit affirmed.