Justia Criminal Law Opinion Summaries

Respondents appealed the district court's grant of habeas relief to petitioner where petitioner had been convicted of first-degree murder. At issue was whether the trial court abused its discretion by precluding defense counsel from cross-examining a witness about a document that contained multiple hearsay. The court held that the trial court's preclusion of cross-examination on the document was not so clearly an abuse of its broad discretion, to balance the probative and prejudicial aspects of potential cross-examination, that the state appellate court's failure to find such an abuse of discretion was an unreasonable application of clearly established law. Therefore, the court reversed the district court's grant of habeas corpus.

Petitioner, proceeding pro se, sought leave to file a successive habeas corpus petition pursuant to 28 U.S.C. 2254 where she was convicted of reckless manslaughter and depraved indifference murder in connection with the death of her infant child. At issue was whether petitioner's due process rights were violated when New York's appellate courts violated her application for a writ of error coram nobis where she alleged that she was denied effective assistance of counsel in her district court appeal. The court denied the petition and held that petitioner did not raise a claim cognizable under section 2254 where a section 2254 petition was not a proper vehicle for challenging deficiencies in a state post-conviction proceeding.

Plaintiff, an African-American, sued defendants pro se alleging violations of 42 U.S.C. 1983 and state law where plaintiff was charged with a traffic violation by a state trooper and where plaintiff alleged that the charge was false and that the trooper's actions were motivated by plaintiff's race. At issue was whether the district court abused its discretion when it denied plaintiff's motion to reopen his case, which the district court had administratively closed, because of plaintiff's failure to obtain counsel. The court held that the district court abused its discretion by denying the motion where the inability of an individual litigant to obtain counsel was not a basis for denying him his statutory right to pursue his case pro se.

Defendant appealed a judgment denying his petition for a writ of habeas corpus where defendant was convicted of Murder in the First Degree for hiring one individual to kill another individual. At issue was whether the trial court erred in admitting a videotaped statement defendant made while in police custody. The court held that the statement was erroneously admitted in violation of defendant's Fifth and Fourteenth Amendment right to counsel where defendant had invoked his right to counsel before making the statements on videotape. The court also held that the error was not harmless where it had a substantial and injurious effect on the jury's verdict. Therefore, the court reversed the judgment and remanded with instructions to grant the writ.

Defendants appealed convictions of murder in aid of racketeering, witness tampering, and conspiracy to commit witness tampering. At issue was whether defendants should have been granted a new trial after the posttrial discovery of the victim's body, whether there were prejudicial errors in the admission of certain testimony by the victim's widow, whether the evidence was sufficient to support their convictions on the witness-tampering counts; and whether the government improperly withheld information that was material to the defense. Also at issue was whether the admission of certain testimony by the victim's daughter was unduly prejudicial and whether the evidence was sufficient to support one of the defendant's conviction of the murder count. The court considered all of defendants' arguments and found them to be without merit and therefore, the judgment of the district court was affirmed.