Richardson v. Palmer, No. 18-1434 (6th Cir. 2019)
Annotate this CaseRichardson was convicted of first-degree murder for killing his wife by causing her to fall from a cliff in Pictured Rocks National Park in 2006. The district court denied a federal habeas petition that claimed prosecutorial misconduct and ineffective assistance of trial and appellate counsel for failing to argue that a witness’s testimony was obtained as a result of an illegal, warrantless search. The Sixth Circuit affirmed. Richardson failed to demonstrate that the Michigan Court of Appeals’ rejection of his claims was objectively unreasonable based on Supreme Court precedent. The prosecutor’s reference to the September 11 terrorist attacks in the context of explaining circumstantial evidence and his references to two notorious murders were unnecessarily provocative but did not so infect the trial as to violate Richardson’s due process rights. Although the prosecutor did elicit testimony that Richardson had called his attorney, the purpose of the questioning was to elicit testimony concerning Richardson’s consciousness of guilt. The court also rejected claims based on the prosecutor’s presentation of “overwhelming evidence” of Richardson’s bad character, denigration of defense counsel and witnesses, and allegedly improper objections. Even if Richardson could demonstrate that his counsel was deficient for failing to make an argument that may have been futile at the time of his trial, he cannot demonstrate that he was prejudiced by counsel’s performance.
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