Woods v. Sinclair

First, waiver of the right to counsel must be unequivocal; second, Confrontation Clause rights are violated if trial error results in actual prejudice; third, to determine whether evidence was withheld at trial in violation of Brady v. Maryland, evidence must be shown to be exculpatory or impeaching, leading to actual prejudice and a reasonable probability that admitting the evidence would have lead to a different result in the trial proceeding; fourth, in order to prevail on an ineffective counsel claim and to excuse a procedurally barred claim under Martinez v. Ryan, substantiality and actual ineffectiveness must be established.

In 1997, Dwayne Woods was sentenced to death for two counts of aggravated murder and one count attempted murder. After the Washington Supreme Court denied Woods’ claim for post-conviction relief, he filed a 28 U.S.C. § 2254 habeas corpus petition in federal district court. Woods claimed that: (1) he was denied the Sixth Amendment right to self-representation; (2) admission of certain evidence violated the Confrontation Clause; (3) the trial court erred in precluding the jury from viewing certain evidence; and (4) counsel was ineffective. The district court dismissed the habeas petition and the Ninth Circuit affirmed. On remand from the United States Supreme Court, the panel held that Woods failed to unequivocally waive his right to counsel because Woods’ pre-trial statement was not clear. Secondly, the panel held that albeit the incorrect application of White v. Illinois to admit certain hearsay evidence at trial, the error in question did not violate the Confrontation Clause because no “actual prejudice” ensued. Thirdly, the panel held that the district court correctly applied Brady v. Maryland in holding that the destruction of an erroneous DNA draft report by the crime lab, which excluded Woods as a suspect, and the nondisclosure by prosecution of the spillage of a sample of Woods blood was not exculpatory evidence because Woods did not cumulatively demonstrate that it was reasonably probable that the result of the trial would have been altered but for ineffectiveness of counsel. Lastly, the panel held that the district court must address substantiality and infectiveness of counsel requirements under Martinez v. Ryan in order to determine whether Woods can establish cause and prejudice to excuse procedurally barred claims. AFFIRMED in part, VACATED in part, and REMANDED.