Jordan v. Lamanna, No. 20-3317 (2d Cir. 2022)
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Petitioner was convicted of manslaughter for administering a fatal dose of prescription medication to her son. The courtroom was closed to spectators for fifteen minutes, during which the prosecutor addressed a website and an email detailing complaint by Petitioner that her trial was unfair. Petitioner moved to set aside her conviction on the ground that her Sixth Amendment right to a public trial had been violated. The district court, on a petition for a writ of habeas corpus, concluded that the Appellate Division had unreasonably applied clearly established federal law in holding that there was no Sixth Amendment violation.
The Second Circuit reversed the district court’s order granting Petitioner’s writ and remanded with instructions to the district court to deny the petition. The court held that the ruling of the New York Appellate Division was not "contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States.” The court reasoned that Antiterrorism and Effective Death Penalty Act ("AEDPA") claims are "adjudicated on the merits" if the state court ruled on the substance of the claim rather than on a procedural ground. Further, a writ cannot be granted "simply because . . . the relevant state-court decision applied clearly established federal law erroneously or incorrectly." The court concluded that based on the relevant Supreme Court decisions, there are at least reasonable arguments supporting the Appellate Division's ruling, which is enough to preclude habeas relief.
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