Mays v. Clark, No. 12-17189 (9th Cir. 2015)Annotate this Case
Petitioner, convicted of first degree murder and sentenced to life in prison without possibility of parole, appealed the denial of his petition for habeas relief. The court concluded that the California Court of Appeal’s ruling that no Miranda violation occurred was an unreasonable application of clearly established Supreme Court precedent. In this case, the state court unreasonably applied Miranda v. Arizona and Davis v. United States by concluding that petitioner's invocation of the right to counsel was ambiguous or equivocal. The state court also contravened or unreasonably applied Smith v. Illinois when it used petitioner’s post-invocation responses to cast doubt on the clarity of his request for counsel. The court concluded, however, that the state court's finding that any Miranda violation was harmless was not unreasonable in light of a witness's statements. Accordingly, the court affirmed the judgment.