Pitts v. Mississippi

Pitts's post-conviction petition invokes Brady and Strickland to challenge either prosecutorial suppression of exculpatory evidence or trial counsel's deficient performance in his Mississippi conviction or sentence. Under AEDPA's deferential standard, federal review of state post-conviction proceedings requires Pitts to demonstrate that Mississippi courts acted contrary to, or unreasonably applied, clearly established Brady or Strickland precedent—a high bar that depends on whether the alleged withheld evidence or counsel's performance was objectively unreasonable and prejudicial to the outcome. The materiality inquiry and Strickland's deficiency and prejudice prongs turn on the specific evidence or conduct at issue and its cumulative impact on trial reliability in what appears to be a serious felony or capital case.