O'Neal v. Balcarcel, No. 18-2201 (6th Cir. 2019)
Annotate this CaseIn 2004, O’Neal was convicted in state court of the second-degree murder of Shelby, who was shot at a gas station. He was sentenced as a habitual offender to 36-80 years in prison. At trial, O’Neal argued that Hickman had shot Shelby. Over O’Neal’s objections, the court excluded Hickman’s jailhouse confession to another inmate and Shelby’s statement to a police officer at the hospital where he died, identifying Hickman as the shooter. The statement was also overheard by a nurse. Hickman had pleaded guilty to manslaughter, which carried a sentence of 3-15 years' imprisonment, in exchange for his testimony at O’Neal’s murder trial. The district court granted O’Neal habeas relief under 28 U.S.C. 2254. The Sixth Circuit affirmed, rejecting the state’s argument that the Michigan Court of Appeals reasonably determined that the erroneous exclusion of the statements was harmless. The district court properly granted relief based on the exclusion of the jailhouse statement because of its potentially profound impact on jurors, particularly when added to the already considerable admitted evidence indicating that Hickman, not O’Neal, was the shooter. Had the hospital identification been admitted, it would have joined an impressive array of evidence that Hickman was the shooter.
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