Hodge v. Mendonsa, No. 13-1825 (1st Cir. 2013)
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After a jury trial in a Massachusetts state court, Petitioner was convicted of second-degree murder and sentenced to life imprisonment. The Massachusetts Appeals Court (MAC) affirmed. The federal district court granted Petitioner’s petition for a writ of habeas corpus by reaching the merits of Petitioner’s arguments on its own without deferring to the state court decision as required by the Antiterrorism and Effective Death Penalty Act, concluding (1) the MAC did not adjudicate Petitioner’s due process claims as presented at trial on the merits, and (2) constitutional error on the part of the trial court was not harmless. The First Circuit Court of Appeals reversed the petition for habeas corpus relief, holding (1) although the MAC did not expressly discuss Petitioner’s arguments regarding the admissibility of evidence under Chambers v. Mississippi, the MAC correctly rejected the argument on the merits; and (2) to the extent the MAC found in a footnote that Petitioner asserted on appeal a new third-party culprit theory of admissibility that was never raised in the trial court, review of the third-party culprit theory was procedurally barred.
The court issued a subsequent related opinion or order on January 10, 2014.
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