Monday, June 07, 2010

Published Cases from Last Week +

Thanks to our AFPDs for their summaries. I'll try to get the unpublished cases up soon.... Also, new format: each case will be an individual, labeled post for easier reference.


State Habeas


Jury convicted defendant of murdering his neighbor, and the trial court sentenced him to life in prison. Unable to obtain relief from the state courts, the defendant petitioned the district court for a writ of habeas corpus. The district court granted the writ, and held that the state courts denied the defendant his constitutional right to present a complete defense when he was unable, under state evidentiary rules, to present propensity evidence designed to show that someone else (namely, the prosecution’s key witness) committed the murder. Appellate Court reversed.

The issue decided in the petitioner’s favor by the district court was reversed by the Circuit Court, which was relying on case law that developed after the District Court had decided to grant the writ. A concurring opinion reads more like a dissent, arguing that the intervening case law was wrongly decided and that, but for following precedent, this would have been a dissent.

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