Woodall v. Simpson, No. 09-5352 (6th Cir. 2012)
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Woodall pled guilty to capital murder, capital kidnapping, and first degree rape in connection with the 1997 murder of a 16-year-old girl. After a penalty trial, the trial court adopted the recommendation of the jury and sentenced Woodall to death on the murder conviction and life imprisonment for the remaining convictions. Woodall unsuccessfully appealed his sentence to the Kentucky Supreme Court and then filed a writ of habeas corpus in federal district court. The district court granted the petition because the trial court denied him his Fifth Amendment right against self-incrimination by refusing to give a requested “no adverse inference” instruction with respect to Woodall not testifying and made a constitutional error during jury selection in allowing the prosecution to use a peremptory challenge to strike an African-American member of the jury without holding a hearing pursuant to Batson. The Sixth Circuit affirmed.
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