Contreras v. Artus, No. 13-1117 (2d Cir. 2015)
Annotate this CasePetitioner, convicted of, inter alia, rape and unlawful imprisonment of his estranged wife, appealed the dismissal of his petition for a writ of habeas corpus under 28 U.S.C. 2254. Petitioner argued that the state trial court violated his constitutional rights to be present during critical stages of trial and to effective assistance of counsel. The state court's affirmance of the exclusion of a note written by the victim for lack of relevance was not based on an unreasonable determination of the facts. Although petitioner argues that the state courts and the district court could not properly reach these conclusions because he was excluded from the Admissibility Hearing, petitioner had provided no basis for impeaching the state courts' factual findings. Petitioner's contention that the state courts' determinations as to relevance were based on unreasonable factual findings is meritless. Given the court's limited role under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) to review habeas petitions to set aside state-court judgments, the court held that the New York courts rejecting petitioner's constitutional claims were not "contrary to" or an "unreasonable application of" clearly established Supreme Court precedent. Accordingly, the court affirmed the judgment of the district court.
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