Jenkins v. Bergeron, No. 15-1081 (1st Cir. 2016)
Annotate this CaseJenkins was convicted in Massachusetts state court in 2005 of the first-degree murder of his cousin and was sentenced to life in prison. He did not testify. The state trial court denied Jenkins's motion for a new trial, and the Supreme Judicial Court (SJC) affirmed. The federal district court denied his habeas petition and granted a certificate of appealability only on the issue of Jenkins's waiver of his right to testify in his own defense. Jenkins argued that his attorney unilaterally decided that he would not testify. The First Circuit affirmed the denial, engaging in deferential review under the Antiterrorism and Effective Death Penalty Act of 1996, 28 U.S.C. 2254(d) because the SJC adjudicated Jenkins's claim on the merits . Because there is no Supreme Court precedent clearly establishing the proper standard and burdens for assessing whether a criminal defendant has validly waived his right to testify on facts like these, Jenkins is not entitled to habeas relief. His claim depends on too broad a characterization of waiver of federal constitutional rights, not drawn from cases of like circumstances.
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