Reiner v. Woods, No. 18-1413 (6th Cir. 2020)
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Reiner’s convictions arose from a 2011 Macomb County home invasion. Eisenhardt, age 69, was stabbed in the neck; jewelry was taken from her house, including a ring from Eisenhardt’s finger. Eisenhardt survived but suffered declining health after the stabbing and died months later. Police in New York apprehended Reiner days after the incident, on unrelated suspicion of driving a stolen vehicle. At his Michigan murder trial, the court admitted the statements to the police, in which a pawnbroker identified Reiner as having pawned Eisenhardt’s ring. The pawnbroker died before trial. The Michigan Court of Appeals upheld Reiner’s conviction, finding the Sixth Amendment error harmless.
The Sixth Circuit reversed the denial of habeas relief, 28 U.S.C. 2254. The evidence presented at trial “paints the picture of a circumstantial case lacking physical evidence or eyewitness testimony placing Reiner at the crime scene.” The statements that caused the Sixth Amendment violation were the linchpin of the government’s case, connecting Reiner to the fruits of the crime in a way no other evidence could. Without those statements, the prosecution’s case would have been significantly weaker, such that “grave doubt” exists as to whether their admission had a “substantial and injurious effect or influence in determining the jury’s verdict.”
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