Brandon Lacy v. Dexter Payne, Director, Arkansas Division of Correction

Summary

The United States District Court for the Eastern District of Arkansas denies Brandon Lacy’s remaining motion to alter or amend the judgment and denies his motion to file a supplemental habeas petition. The court concludes that newly produced prosecutor’s files do not establish manifest error, prejudice, or grounds to overcome procedural defaults on Lacy’s claims concerning ineffective assistance, medical-examiner testimony, victim-family views, and jail correspondence. The proposed supplemental claims are denied as futile and, in one instance, unduly delayed.

Holdings

1. The Rule 59(e) motion was properly denied because Lacy did not demonstrate manifest error of law or fact, and the newly produced materials did not undermine the judgment.
2. The prosecutor-file materials did not establish cause or prejudice sufficient to overcome procedural default, and the related claims remained meritless.
3. Leave to supplement was denied because the proposed claims were futile and, for at least one claim, unduly delayed.

Questions Presented

1. Whether newly obtained prosecutor-file materials demonstrated manifest error of law or fact warranting alteration or amendment of the judgment under Rule 59(e).
2. Whether the prosecutor-file materials established cause or prejudice sufficient to excuse procedural default of Lacy's claims.
3. Whether the materials supported a meritorious Brady, Napue, or prosecutorial-misconduct claim.
4. Whether Lacy should receive leave under Rule 15(a)(2) to file supplemental habeas claims.
5. Whether the proposed supplemental claims were futile or unduly delayed.

Disposition

other