David Lynn Richards, Jr. v. Tennessee

David Lynn Richards, Jr., a business owner and minister who has always maintained his innocence, was wrongfully convicted of sexually abusing one of his adopted children, A.M.R. The trial court described this as a “close case” and found both A.M.R. and Mr. Richards credible, but the jury found him guilty, having heard damning one-sided expert testimony which allowed the State to argue that Mr. Richards’ semen was in A.M.R.’s bedroom and he “wiped” their iPhones to hide evidence. After trial, Mr. Richards retained new counsel who learned the State’s DNA expert resigned in lieu of termination for falsifying records; new counsel also presented experts who explained that Mr. Richards’ semen wasn’t found, the source of the semen could have been canine, his phone was re-set while in police custody, A.M.R.’s phone was re-set while she had access to it, and A.M.R. suffered from significant mental health disorders. Tennessee courts denied relief, reasoning that no one claim would have changed the outcome, no “cumulative error” existed because no individual errors were proven, and no greater in camera review of confidential materials was warranted. The issues are: (1) Do Tennessee’s interpretations of Brady v. Maryland, 373 U.S. 83 (1963), and Strickland v. Washington, 466 U.S. 668 (1984), conflict with this Court’s instruction to conduct holistic reviews? (2) Despite Hinton v. Alabama, 571 U.S. 263 (2014), and Harrington v. Richter, 562 U.S. 86 (2011), may Tennessee courts defer to counsel’s uninformed decisions? (3) Should the Court clarify when Pennsylvania v. Ritchie, 410 U.S. 39 (1987), permits in camera review and disclosure?