Marrio Williams v. Secretary, Department of Corrections

Summary

The United States District Court for the Middle District of Florida denies Marrio Williams’s petition for a writ of habeas corpus under 28 U.S.C. § 2254, challenging his Florida first-degree murder conviction and life sentence. The order concludes that the petition was timely and rejects claims concerning DNA testing, competency to stand trial, and counsel’s motion for judgment of acquittal, applying AEDPA and Strickland standards. The court also denies a certificate of appealability.

Holdings

1. Williams was not entitled to habeas relief because he failed to demonstrate actual prejudice from the denial of DNA testing of cigarette butts found near the murder scene.
2. The state court reasonably rejected Williams's claim that counsel was ineffective for failing to investigate competency or request a competency determination.
3. Williams failed to show that counsel was ineffective in moving for judgment of acquittal because counsel reasonably argued that the State had not established a prima facie case.
4. Williams could not establish Strickland prejudice from counsel's failure to request an instruction on manslaughter by culpable negligence.
5. Williams failed to show ineffective assistance based on counsel's allegedly underdeveloped motion for new trial.
6. Williams failed to establish prejudice from counsel's alleged failure to initiate plea negotiations because the prosecution made no plea offer.
7. Williams failed to establish prejudice from counsel's failure to investigate or obtain surveillance footage from a nearby bank.

Questions Presented

1. Whether the state trial court's denial of Williams's request for DNA testing of cigarette butts found near the murder scene violated due process or caused actual prejudice.
2. Whether trial counsel was ineffective for failing to investigate and request a competency determination before trial.
3. Whether trial counsel was ineffective for failing to make an adequate motion for judgment of acquittal.
4. Whether trial counsel was ineffective for failing to request a jury instruction on manslaughter by culpable negligence.
5. Whether trial counsel was ineffective for filing an allegedly underdeveloped motion for new trial.
6. Whether trial counsel was ineffective for failing to initiate plea negotiations before trial.
7. Whether trial counsel was ineffective for failing to investigate or obtain surveillance footage from a nearby bank.

Disposition

dismissed