Winfield v. O'Brien, No. 13-2438 (1st Cir. 2014)
Annotate this CaseAfter a jury trial in Massachusetts state court, Petitioner was convicted of assaulting and raping a two-year-old child and sentenced to life imprisonment. Petitioner’s application for further appellate review was denied. Petitioner filed this petition for a writ of habeas corpus in the federal district court, arguing (1) the evidence against him, which was entirely circumstantial, was so insufficient that no reasonable jurist could have concluded that a rational jury could have found him guilty beyond a reasonable doubt; and (2) the trial court erred in refusing to permit him to cross-examine the victim’s mother about her potential bias arising from pending criminal charges against her. The district court denied the petition but issued a certificate of appealability as to both issues. The First Circuit affirmed, holding (1) the state courts could reasonably conclude that a rational jury could find beyond a reasonable doubt that Petitioner was the perpetrator; and (2) the state court’s exclusion of evidence about the victim’s mother’s pending criminal charges was not an unreasonable application of law clearly established by Supreme Court precedent.
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