Garlick v. Lee, No. 20-1796 (2d Cir. 2021)
Annotate this CaseThe Second Circuit affirmed the district court's grant of a petition for habeas relief to petitioner, who was convicted by a jury in state court of first degree manslaughter. The court concluded that the admission of the autopsy report at petitioner's trial through a surrogate witness was an unreasonable application of clearly established Supreme Court precedent. See Crawford v. Washington, 541 U.S. 36, 40 (2004); Melendez-Diaz v. Massachusetts, 557 U.S. 305 (2009); and Bullcoming v. New Mexico, 564 U.S. 647 (2011). Furthermore, the unreasonably erroneous admission of the autopsy report was not harmless where the report was the strongest evidence in the State's case and was not cumulative of other inculpatory evidence connecting petitioner to the victim's death.
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