Louise Harris v. Jefferson S. Dunn, Commissioner, Alabama Department of Corrections

1.(a) Whether the Alabama trial court’s appointing nine different lawyers to defend Petitioner—a woman with at best a 77-79 IQ and who had been abused by her three husbands and her codefendant lover— constituted a structural error applying the principles underlying this Court’s decisions in Gideon v. Wainwright 372 U.S. 335 (1963) and United States v. Cronic, 466 U.S. 648 (1984), such that Petitioner was not required to show prejudice. 1.(b) Where a claim of ineffective assistance of counsel is based on the Alabama trial court’s appointing and then relieving seven different lawyers for Petitioner, ultimately settling on her eighth and ninth lawyers to try the case, and the jury never heard that Petitioner has at best a 77-79 IQ, was abused by her three husbands and codefendant lover and, Petitioner testified with disastrous results, must the Court make the reasonable inference of “a causal link between the discontinuity of counsel and resulting errors at trial”? 1.(c) Whether the Court of Appeals for the Eleventh Circuit erred in denying a Certificate of Appealability to Petitioner on the issue of whether the cumulative errors of her counsel rendered them ineffective. 2.(a) Is a pattern of strikes sufficient to establish a prima facie case of discriminatory use of peremptory strikes under Batson v. Kentucky, 476 U.S. 79 (1986), where defendant demonstrates that: (i) the prosecutors used 12 of their 19 peremptory challenges to strike 12 of 18