failure to move for a change of venue rendered Franqui’s convictions materially unreliable, and the court's failure to provide for such a change violated his constitutional rights; (4) Franqui was deprived of his right to adversarial testing and effective assistance of counsel at the penalty phase, thus rendering his death sentence unreliable and unconstitutional; (5) Franqui's convictions are materially unreliable because counsel failed to present the testimony of Franqui’s wife, Vivian Gonzalez, at the hearing on the motion to suppress his confession to support his claim of invocation of counsel and at trial to testify to his condition during interrogation; (6) Franqui’s convictions and sentences are materially unreliable because of counsel’s failur 2242, 153 L.Ed.2d 335 (2002) (<HOLDING>). On March 19, 2003, Franqui filed a supplement
holding that under the eighth amendment to the united states constitution the government may not execute a mentally retarded person holding execution of the mentally retarded constitutes cruel and unusual punishment in violation of the eighth amendment holding that the execution of mentally retarded criminals violates the eighth amendment holding that execution of the mentally retarded is prohibited under the eighth amendment to the united states constitution holding execution of mentally retarded individuals fails to achieve legitimate penalogical objectives for punishment as required by the eighth amendment to the united states constitution and article i  16 of the tennessee constitution