Engle v. Lumpkin, No. 19-40356 (5th Cir. 2022)
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Petitioner was convicted of felony aggravated assault with a deadly weapon. Petitioner initiated a postconviction proceeding in federal district court. The district court rejected all of Petitioner’s claims of trial error. Petitioner then sought a certificate of appealability.
The Fifth Circuit affirmed the district court’s judgment and denied Petitioner’s habeas relief. The court held that while certain conduct by the prosecutor during the trial violated the Due Process Clause, Petitioner was not prejudiced by the violation. The court analyzed Petitioner’s collateral attack on his state criminal conviction under the federal Antiterrorism and Effective Death Penalty Act (AEDPA). Here, at the outset of custodial interrogation following his arrest, the Ranger gave Petitioner the statutorily required warning that he “ha[d] the right to terminate the interview at any time.” Petitioner immediately invoked this right. The prosecutor subsequently relied on that invocation at trial as evidence of Petitioner’s sanity. The State pointed out that, although Miranda established a right to terminate custodial questioning, this was not one of the rights of which the Court held that suspects must be apprised before questioning begins.
The court concluded that the prosecutor violated the Due Process Clause when he used Petitioner’s invocation of his right to terminate custodial interrogation as evidence of sanity. However, the court further held that the fact that Petitioner’s due-process rights were violated does not necessarily mean that he is entitled to habeas relief. Here, he failed to demonstrate prejudice or that the constitutional violation had a substantial effect on the verdict.
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