Blanton's childhood injuries (including a childhood bike accident where Blanton injured his head), his difficult upbringing, and his abuse of damaging inhalants. According to Mr. Potter's report, organic brain damage to the frontal lobe of Blanton's brain would fundamentally alter how *238 he perceived the world, reacted to stress, controlled impulses, and conformed to social norms.
During Blanton's state habeas proceeding, lead trial counsel testified that he and the mitigation specialist had trouble obtaining some of Blanton's medical records from another state. He admitted that if they had looked sooner, they likely could have obtained them. Lead trial counsel admitted that the prosecution "shredded" his mitigation expert on cross examination, but stated that the mitigation expert provided the jury with useful information nonetheless. In hindsight, trial counsel would haveshuffle, after the shuffle the first African-American was at position 64. Based on the concentration of African-American panel members at the front, he argued there was a great likelihood that a shuffle would move them back in the order. The prosecutor testified that she requested the jury shuffle based not on race, but on the occupations of the venire members. The state habeas court accepted the prosecutor's race-neutral justification for the jury shuffle.
The district court questioned the prosecutor's race-neutral justification for the jury shuffle. In fact, the district court stated that it found "no correlation between the occupation based concerns voiced by the lead prosecutor ... and the composition of petitioner's initial venire panel." Blanton v. Quarterman, 489 F.Supp.2d. at 704. In reaching this conclusion, the district court