Littlejohn v. Royal

An Oklahoma jury convicted Emmanuel Littlejohn of first-degree murder and sentenced him to death. In this case's first appearance before the Tenth Circuit, the district court found Littlejohn’s ineffective-assistance and cumulative-error claims (among twelve other bases for relief) meritless or procedurally barred. The Tenth Circuit addressed the declaration of Dr. Manual Saint Martin, a psychiatrist who diagnosed Littlejohn (for the first time) with undefined, synapse-level neurological deficits, or an organic brain disorder. Given that evidence, the Court reasoned that the disposition of Littlejohn’s ineffective-assistance claim, and derivatively, his cumulative-error claim, hinged on whether Dr. Saint Martin’s averments would prove worthy of belief, because “[e]vidence that an organic brain disorder was a substantial factor in engendering Mr. Littlejohn’s life of deviance probably would have been a significant favorable input for Mr. Littlejohn in the jury’s decisionmaking calculus” during the penalty phase. As a result, the case was remanded to the district court for an evidentiary hearing on whether Littlejohn’s trial counsel proved ineffective by failing to adequately investigate and present to the jury a mitigation theory of organic brain damage. On remand, the district court held an evidentiary hearing; the parties presented the testimony of various individuals - including Dr. Saint Martin and Littlejohn’s trial counsel. Following the hearing, the district court largely restated its earlier findings and again denied Littlejohn habeas relief on his ineffective-assistance and cumulative-error claims. Littlejohn appealed the district court’s judgment on remand. With the benefit of a more developed factual record relative to Littlejohn’s alleged organic brain damage, the Tenth Circuit found no reversible error and affirmed the district court. View "Littlejohn v. Royal" on Justia Law