Cronin v. Comm’r of Probation, No. 14-1580 (1st Cir. 2015)
Annotate this CaseAfter a jury trial in a Massachusetts state court, Petitioner was found guilty of operating a motor vehicle under the influence of alcohol, third offense, and negligent operation of a motor vehicle. Petitioner appealed, asserting that the prosecutor’s comments during cross-examination and closing argument constituted unconstitutionally forbidden commentary on his post-Miranda silence. The Massachusetts Appeals Court (MAC) affirmed, and the Supreme Judicial Court summarily denied Petitioner’s application for further appellate review. Thereafter, Petitioner sought habeas relief in the federal district court, arguing that the MAC’s decision was contrary to or an unreasonable application of clearly established federal law because the prosecutor’s questions and comments on his post-Miranda silence contravened Doyle v. Ohio and, therefore, abridged his due process rights. The district court denied habeas relief. The First Circuit affirmed, holding that even if the MAC misapplied the Doyle rule and a Doyle error occurred, any comment on Petitioner’s silence was harmless when considered in the context of the trial as a whole.
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