Brown

Facts

After raping and murdering Holly Washa,1 Brown was con- victed of aggravated first-degree murder in Washington. With the aid of an investigator, a social worker and a mitigation specialist, Brown’s three experienced attorneys put on a thor- ough mitigation case during the penalty phase of Brown’s trial. They (1) created a 250-page life chronology detailing Brown’s social and medical history, and presented most of this information at trial; (2) introduced evidence that Brown had a mental disorder; (3) called Dr. Maiuro, a clinical psy- chologist; and (4) called multiple character witnesses, such as family members. Nonetheless, the jury sentenced Brown to death.

After exhausting his direct appeals and state collateral review, Brown petitioned for a writ of habeas corpus in fed- eral court, raising a number of constitutional claims regarding his trial and sentencing.2 The district court denied his petition 1 For a more detailed discussion of the facts, see the Washington Supreme Court’s opinion in Brown’s direct appeal, State v. Brown, 940 P.2d 546, 555-59 (Wash. 1997) (en banc). 2 Because Brown filed his habeas petition after April 23, 1996, we apply the “substantive review…