Keith Whitmore v. Superintendent Forest SCI

CourtCourt of Appeals for the Third Circuit
DecidedMarch 13, 2026
Docket22-2237
StatusUnpublished

This text of Keith Whitmore v. Superintendent Forest SCI (Keith Whitmore v. Superintendent Forest SCI) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Keith Whitmore v. Superintendent Forest SCI, (3d Cir. 2026).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ____________

No. 22-2237 ____________

KEITH WHITMORE,

Appellant

v.

SUPERINTENDENT FOREST SCI; THE DISTRICT ATTORNEY OF THE COUNTY OF PHILADELPHIA; THE ATTORNEY GENERAL OF THE COMMONWEALTH OF PA ____________

On Appeal from the United States District Court for the Eastern District Pennsylvania (D.C. Civil No. 2:20-cv-01390) District Judge: Honorable Gene E. K. Pratter ____________

Argued on December 10, 2025

Before: KRAUSE, PHIPPS and FISHER, Circuit Judges.

(Filed: March 13, 2026)

Rosemary Auge ARGUED Federal Community Defender Office for the Eastern District of Pennsylvania Capital Habeas Unit 601 Walnut Street The Curtis Center, Suite 545 West Philadelphia, PA 19106

Peter F. Andrews ARGUED David Napiorski Anthony Salzetta Philadelphia County Office of District Attorney 3 S Penn Square Philadelphia, PA 19107

____________

OPINION* ____________

FISHER, Circuit Judge.

Although habeas relief is difficult to obtain, a court must provide each petitioner a

fair opportunity. Keith Whitmore never received that opportunity. In his habeas petition,

Whitmore alleges that he informed his trial counsel that Officer Dennis Johnson, a critical

witness, was biased against him and that his trial counsel failed to investigate Johnson’s

bias. Without the information that might have been discovered through investigation,

Whitmore’s trial counsel failed to impeach Officer Johnson. Whitmore was subsequently

convicted of first-degree murder, as well as other serious crimes, and received a

mandatory life sentence without parole. Whitmore’s allegations, if true, show ineffective

assistance. But neither the state nor the federal district court gave Whitmore a chance to

prove those allegations. We will remand for an evidentiary hearing and give him that

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent.

2 chance.1

Because the state court denied Whitmore’s petition on the merits, we can grant

him federal habeas relief only if the state court’s decision is contrary to clearly

established federal law or is an unreasonable application of that law.2 The state court’s

decision is neither. First, the Superior Court used the governing Strickland v.

Washington3 standard and, therefore, applied the correct legal rule.

Second, Whitmore cannot show that the Superior Court unreasonably applied

Strickland. True, counsel’s failure to conduct a pretrial investigation generally constitutes

ineffective assistance.4 And Whitmore swears that, although he informed his trial counsel

about Johnson’s harassing, intimidating, and threatening him because of his relationship

with Johnson’s niece, counsel failed to investigate this bias. But only Whitmore’s self-

serving affidavit supports these allegations. So, the Superior Court correctly ruled that, at

1 The District Court had jurisdiction under 28 U.S.C. § 2254(a) (habeas corpus). We have jurisdiction under 28 U.S.C. §§ 1291 (final decisions of district courts) and 2253(a) (habeas corpus appeals). 2 28 U.S.C. § 2254(d)(1). 3 466 U.S. 668, 687 (1984). Under Pennsylvania law, the familiar two-part Strickland analysis is a three-part test. “[T]o prove counsel ineffective, the petitioner must show that: (1) his underlying claim is of arguable merit; (2) counsel had no reasonable basis for his action or inaction; and (3) the petitioner suffered actual prejudice as a result.” Commonwealth v. Spotz, 84 A.3d 294, 311 (Pa. 2014). Despite the additional prong, the Pennsylvania standard is identical to Strickland. Commonwealth. v. Pierce, 527 A.2d 973, 977 (Pa. 1987); Werts v. Vaughn, 228 F.3d 178, 203–04 (3d Cir. 2000). 4 United States v. Gray, 878 F.2d 702, 711 (3d Cir. 1989); see also Strickland, 466 U.S. at 690–91.

3 that time, “the record [did] not support” Whitmore’s claim.5

However, Whitmore never got the opportunity to develop that record. Although he

repeatedly requested an evidentiary hearing, neither the state nor the district court gave

him one. Because Whitmore alleges facts that, if proven, would entitle him to federal

habeas relief, the District Court should have given him a hearing.

Both statute and precedent limit a habeas petitioner’s ability to get an evidentiary

hearing. We conclude—and each party agrees6—that neither limit applies here. Under 28

U.S.C. § 2254(e)(2), a federal district court may not hold an evidentiary hearing if the

petitioner “has failed to develop the factual basis of a claim in State court proceedings.”

But Whitmore never “failed to develop the factual basis of [his] claim.”7 He promptly

sought “an evidentiary hearing in the manner required by state law,”8 but the state court

refused. Because Whitmore is again asking for his first bite at the apple, § 2254(e)(2)’s

bar does not apply.

The Supreme Court explained in Cullen v. Pinholster “that review under

§ 2254(d)(1) is limited to the record that was before the state court that adjudicated the

claim on the merits.”9 We reasoned that, “[i]n light of Pinholster, district courts cannot

conduct evidentiary hearings to supplement the existing state court record under 28

5 App. 500. 6 Appellant’s Br. 46–48; Appellees’ Br. 36 n.2. 7 28 U.S.C. § 2254(e)(2). 8 Morris v. Beard, 633 F.3d 185, 195 (3d Cir. 2011). 9 563 U.S. 170, 181 (2011).

4 U.S.C. § 2254(d).”10 But “there is an exception when the state court has denied the

petitioner a hearing because it thought that he would lose even if his allegations were

presumed true.”11 In such a circumstance, “Pinholster’s bar does not apply if that ruling

was unreasonable as a matter of clear federal law.”12

Whitmore satisfies this exception. The Superior Court rested its conclusion that

Whitmore’s allegations “lack[ed] arguable merit” on two alternative grounds.13 One was

that “the record does not support a finding that counsel was even aware of the supposed

animosity Johnson harbored toward Whitmore.”14 But the other was that, even accepting

the truth of Whitmore’s “self-serving affidavit,” Whitmore needed “to produce []

evidence to corroborate this allegation” in order to meet the threshold for “arguable

merit.”15 That is, because the Superior Court found that Whitmore’s allegations, even if

true, would not merit relief, the Superior Court denied Whitmore’s request for a hearing

and dismissed his petition.16 But, as we explain below, Whitmore “has alleged facts that

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Schriro v. Landrigan
550 U.S. 465 (Supreme Court, 2007)
Morris v. Beard
633 F.3d 185 (Third Circuit, 2011)
United States v. Tyrone Anthony Gray
878 F.2d 702 (Third Circuit, 1989)
Brown v. WENEROWICZ
663 F.3d 619 (Third Circuit, 2011)
Marshall v. Hendricks
307 F.3d 36 (Third Circuit, 2002)
Commonwealth v. Pierce
527 A.2d 973 (Supreme Court of Pennsylvania, 1987)
Commonwealth v. Jones
876 A.2d 380 (Supreme Court of Pennsylvania, 2005)
Commonwealth v. Barnett
121 A.3d 534 (Superior Court of Pennsylvania, 2015)
Pollock v. Brayton
162 N.E. 608 (Ohio Court of Appeals, 1924)
Doran v. Bethards
160 N.E. 110 (Ohio Court of Appeals, 1927)
Commonwealth v. Spotz
84 A.3d 294 (Supreme Court of Pennsylvania, 2014)
John Lesko v. Secretary Pennsylvania Departm
34 F.4th 211 (Third Circuit, 2022)
Cullen v. Pinholster
179 L. Ed. 2d 557 (Supreme Court, 2011)
Jordan v. Hepp
831 F.3d 837 (Seventh Circuit, 2016)
Khamal Fooks v. Superintendent Smithfield SCI
96 F.4th 595 (Third Circuit, 2024)
Kay Ellison v. United States
120 F.4th 338 (Third Circuit, 2024)

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Keith Whitmore v. Superintendent Forest SCI, Counsel Stack Legal Research, https://law.counselstack.com/opinion/keith-whitmore-v-superintendent-forest-sci-ca3-2026.