Valdez v. Cockrell

Alberto Valdez (defendant) was sentenced to death in 1988 for the murder of a police sergeant. Valdez raised 24 legal issues in a state habeas petition, including an ineffective-assistance-of-counsel (IAC) claim, alleging that trial counsel failed to investigate Valdez’s background and present mitigation information on Valdez’s intellectual disability, history of child abuse, and model behavior during previous incarceration terms. The state habeas court held a two-day evidentiary hearing and then denied Valdez’s petition a month later, finding in relevant part that IAC did not occur but that if IAC did occur, Valdez was not prejudiced. The Texas Court of Criminal Appeals affirmed the denial of state habeas relief in a one-page order. Valdez then filed a federal habeas petition, and after an evidentiary hearing, the district court granted Valdez relief on the IAC issue, noting that it largely did not defer to the state court’s findings because the state court denied Valdez a full and fair hearing. The federal district court believed that Valdez’s state habeas hearing was unfair primarily because (1) the state judge admitted at a hearing that he had never read Valdez’s trial record and (2) the habeas court lost its hearing exhibits, which included documents Valdez produced to prove his intellectual disability, and then decided to exclude those exhibits from its findings. The government appealed.