Leonard Ray Woods v. State

Summary

The Nevada Supreme Court affirmed the denial of Leonard Ray Woods's postconviction petition for a writ of habeas corpus. The court held that several claims were barred by the law-of-the-case doctrine or procedural default, and that Woods failed to establish Brady violations or ineffective assistance of appellate counsel. The court also concluded that the district court did not abuse its discretion in denying appointment of postconviction counsel.

Holdings

1. The law-of-the-case doctrine barred Woods from relitigating his claims concerning the denial of substitute counsel and suppression of evidence recovered from his cell phone because those issues had already been considered and resolved on direct appeal.
2. A petitioner whose Brady claim could have been raised on direct appeal must show good cause for the omission and prejudice; Woods failed to satisfy that requirement because he did not allege specific facts showing that the purported fingerprint, DNA, or physical evidence was favorable, withheld by the State, or material.
3. Woods's claims concerning review of law-enforcement personnel files, standby counsel, defense resources, trial timing, and alleged improper witness influence were procedurally barred because he did not show good cause and prejudice or a fundamental miscarriage of justice.
4. Woods failed to establish ineffective assistance of appellate counsel because he did not show deficient performance or a reasonable probability that any omitted issue would have succeeded on appeal.
5. The district court did not abuse its discretion by denying Woods's request for appointed postconviction counsel.

Questions Presented

1. Whether the law-of-the-case doctrine barred relitigation of Woods's claims concerning substitute counsel and suppression of evidence recovered from his cell phone.
2. Whether Woods established good cause and prejudice under Nevada's postconviction procedural-bar statute for his Brady claim and other claims that could have been raised on direct appeal.
3. Whether Woods demonstrated ineffective assistance of appellate counsel based on counsel's failure to raise the omitted issues.
4. Whether the district court abused its discretion by denying appointment of postconviction counsel.

Disposition

affirmed