Iromuanya v. Frakes, No. 16-1935 (8th Cir. 2017)
Annotate this CaseThe Eighth Circuit affirmed the denial of habeas relief pursuant to 28 U.S.C. 2254 to petitioner. Petitioner raised an ineffective assistance of counsel claim for counsel's deficient performance during plea negotiations and for failing to object to the sudden-quarrel jury instruction as a step instruction for second-degree murder. The court held that petitioner adequately, though possibly inartfully, presented the due process claims to the Nebraska Supreme Court, and that the court adjudicated them; the state court's adjudication was not contrary to, nor did it involve an unreasonable application of, clearly established Supreme Court precedent; and the adjudication also was not based on an unreasonable determination of the facts in light of the evidence presented in the state court proceedings.
Court Description: Beam, Author, with Riley and Shepherd, Circuit Judges] Prisoner Case - Habeas Corpus. Following conviction for attempted second-degree murder and second-degree murder, and exhaustion of his state court remedies,Defendant filed a petition for writ of habeas corpus, arguing the trial court denied him due process by failing to properly instruct the jury on whether jury should have been able to consider sudden-quarrel provocation on the attempt charge and the jury could not consider sudden quarrel unless it found Ironmuanya not guilty to second-degree murder. The district court denied relief. On appeal, we conclude that Ironmuanya fairly presented his due process claims to the state courts. On the merits, after reviewing the history of Nebraska law on the subject, this court concludes the Nebraska Supreme Court's determination that due process was not offended by either the lack of jury instruction or the step jury instruction and the adjudication was not contrary to, nor involve an unreasonable application of, clearly established Supreme court precedent and further was not based on an unreasonable determination of the facts in light of the evidence presented in the state court proceedings.
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