Miller v. Stovall, No. 12-2171 (6th Cir. 2014)
Annotate this CaseMiller was convicted in Michigan of second-degree murder and conspiracy to commit first-degree murder and sentenced to life without parole. The evidence included email and instant-message conversations between Miller and her lover, Cassaday, in which Miller lied to Cassaday that she was pregnant with his children but that her husband abused her, causing her to miscarry; convinced Cassaday that her husband was involved in organized crime and that her life was in danger; and plotted her husband’s murder. Cassaday told his brother Mike that he was leaving town and that, if he did not return, Mike should look for a briefcase under Cassaday’s bed. Bruce Miller was murdered on November 9, 1999. Miller promptly ended her relationship with Cassaday and started dating someone else. Cassaday committed suicide. Mike found the briefcase and notes, which he opened in the presence of an attorney. The case contained copies of the emails and IM conversations. Its contents were admitted into evidence with evidence linking the communications to Miller’s and Cassaday’s AOL accounts. Cassaday’s suicide note was also admitted. Miller claimed that admission of the note violated her clearly established Sixth Amendment right to confront her accuser and sought habeas corpus. Following a remand, after the Supreme Court vacated an earlier decision, the Sixth Circuit affirmed, holding that the Michigan Court of Appeals decision upholding the note’s admission did not violate clearly established law.
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