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Felker v. Thomas

Citations: 52 F.3d 907; 1995 U.S. App. LEXIS 10280Docket: 94-8224

Court: Court of Appeals for the Eleventh Circuit; May 8, 1995; Federal Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

The Eleventh Circuit Court of Appeals upheld the denial of Ellis Wayne Felker's habeas corpus petition under 28 U.S.C. § 2254, following his conviction and death sentence for the murder of Evelyn Joy Ludlam. Felker's appeal raised three primary issues: the sufficiency of evidence, alleged suppression of exculpatory evidence in violation of Brady v. Maryland, and ineffective assistance of counsel during sentencing. The court found no merit in these claims, aligning with the Georgia Supreme Court's decision, which found substantial evidence supporting his conviction. Felker's Brady claim failed as he was aware of the purportedly suppressed evidence prior to trial, and it was not material to his defense. Additionally, the court deemed his counsel's strategy during sentencing—opting not to dispute the jury's guilty verdict but rather focusing on mitigating evidence—reasonable. Consequently, the district court's decision to deny the habeas corpus petition was affirmed, leaving Felker's conviction and death sentence intact.

Legal Issues Addressed

Brady v. Maryland Claim

Application: Felker's Brady claim failed because the evidence was not suppressed, and it was not material as it contradicted his own testimony rather than the prosecution's theory.

Reasoning: Felker’s claim fails on the first and third elements. He cannot demonstrate that the evidence, which suggests he was seen with the victim shortly before her death, was suppressed, as he was aware of it prior to trial.

Habeas Corpus Relief under 28 U.S.C. § 2254

Application: The Eleventh Circuit Court of Appeals reviewed the denial of habeas corpus relief and found no merit in the claims presented by Felker.

Reasoning: The Eleventh Circuit Court of Appeals reviewed the denial of habeas corpus relief under 28 U.S.C. § 2254 to Ellis Wayne Felker, who was convicted of murder and sentenced to death.

Ineffective Assistance of Counsel

Application: The court found Felker's counsel's decision not to dispute the jury's guilty verdict during sentencing to be reasonable and within the range of acceptable professional assistance.

Reasoning: This strategic choice by counsel not to dispute guilt at sentencing was deemed reasonable and within the broad range of acceptable professional assistance, as recognized by legal standards.

Sufficiency of Evidence for Conviction

Application: Felker's claim of insufficient evidence was dismissed as the Georgia Supreme Court had detailed substantial evidence supporting his conviction.

Reasoning: The Georgia Supreme Court had previously detailed substantial evidence against him, concluding that the evidence was sufficient for convictions of false imprisonment, rape, and aggravated sodomy.