Mansfield v. Secretary, DOC, No. 09-12312 (11th Cir. 2012)
Annotate this CaseIn this capital case, the State of Florida appealed the district court's order granting habeas relief to petitioner on his claim that the admission of a videotape of his custodial interrogation by law enforcement officers, when he never received any Miranda warnings, yielded prejudicial constitutional error. The court reversed the judgment of the district court, concluding that the district court engaged in its own factfinding process, failed to accept as correct some of the unrebutted factual findings of the Florida Supreme Court that credited significant pieces of the State's case against petitioner; afforded precious little weight to other pieces of evidence that the Florida Supreme Court fairly relied upon; and ignored entirely still other evidence incriminating petitioner. Accordingly, the court concluded that the admission of the videotaped interrogation amounted to harmless error under the "actual prejudice" standard for collateral review set forth by the Supreme Court in Brecht v. Abrahamson.
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