Hendrix v. Palmer

The Warden appealed the district court's conditional grant of petitioner's application for a writ of habeas corpus under 28 U.S.C. 2254 and petitioner cross-appealed the denial of relief on several alternative claims. The Sixth Circuit held that the Michigan courts adjudicated petitioner's claims on the merits, so the Antiterrorism and Effective Death Penalty Act (AEDPA) elevated standard of review applied. The court affirmed the district court's grant of habeas relief based on petitioner's Fifth and Sixth Amendment claims where the state conceded that petitioner's statements to the police were obtained in violation of his Fifth Amendment rights and the error was not harmless, and trial counsel's failure to challenge the admission of the statements constituted ineffective assistance of counsel. The court also held that the prosecutor's comments on petitioner's post-Miranda silence violated due process; reversed the denial of petitioner's Doyle claim; and affirmed the district court's holding that the evidence was sufficient to support defendant's conviction. View "Hendrix v. Palmer" on Justia Law