Connolly v. Roden, No. 13-1191 (1st Cir. 2014)
Annotate this CasePetitioner was convicted in Massachusetts state court of drug distribution and trafficking. While Petitioner’s appeal was pending in the Supreme Judicial Court (SJC), the U.S. Supreme Court decided Melendez-Diaz v. Massachusetts. On appeal, Petitioner argued that his conviction must be reversed because the trial proceedings violated his federal Confrontation Clause rights as articulated in Melendez-Diaz. The SJC decided that there was a Melendez-Diaz error in this case but that the error was harmless beyond a reasonable doubt. Petitioner petitioned for habeas review in federal district court, arguing that the state proceedings had violated his Sixth Amendment rights under Melendez-Diaz. The district court denied the petition, concluding that Petitioner could not show sufficient injury under the Brecht v. Abrahamson standard of review. The First Circuit affirmed, holding that under the highly deferential standard announced in Brecht, Petitioner failed to show the “substantial and injurious effect or influence” on the verdict required to set aside the SJC’s affirmance of his conviction.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.