Nash v. Russell, No. 15-1466 (8th Cir. 2015)
Annotate this CasePetitioner, convicted of capital murder, appealed the denial of his petition for habeas relief under 28 U.S.C. 2254. Petitioner argued that his conviction is not supported by sufficient evidence and his constitutional rights were violated by Missouri’s “direct connection rule,” under which the trial court excluded evidence of a third-party’s potential guilt. The court concluded that petitioner has not established grounds for federal habeas relief. However, as the district court noted, the newly presented evidence in this case deserves “serious consideration” in the state courts. Although the court rejected petitioner's gateway claim of actual innocence under Schlup v. Delo, the court noted that Missouri provides a procedure for a prisoner to petition for habeas corpus relief in its courts. The court suggested, without weighing in on the merits, that state court would be a more appropriate forum for petitioner's claims.
Court Description: Melloy, Author, with Murphy and Smith, Circuit Judges] Prisoner case - Habeas. The Missouri Supreme Court's conclusion that Nash's murder conviction was supported by substantial evidence is neither incorrect nor unreasonable; Nash's claim that his Sixth Amendment right to present a complete defense was violated when the trial court excluded evidence of a third-party's fingerprints under Missouri's "direct connection rule" was proceduraly barred; with respect to Nash's actual innocence as a gateway claim under Schlup v. Delo, 513 U.S. 298 (1995), the evidence Nash sought to assert was not new and even with the evidence, a reasonable jury could find Nash guilty; without weighing the merits, state court would be a more appropriate forum for Nash's new DNA evidence. [ November 23, 2015
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