Reis-Campos v. Biter, No. 15-15683 (9th Cir. 2016)
Annotate this CasePetitioner appealed the denial of his petition for habeas relief, challenging his 2007 second-degree murder conviction. The court concluded that petitioner correctly alleged that the prosecution concealed evidence that could have bolstered his self-defense claim, in violation of Brady v. Maryland. However, the court concluded that the extremely deferential standard of review does not mandate relief because petitioner was not sufficiently prejudiced. The court also concluded that there was no Antiterrorism and Effective Death Penalty Act (AEDPA) error in rejecting a claim under Napue v. Illinois. Even when combined with the Brady violations, there is no reasonable probability that the result of the proceeding would have been different. Accordingly, the court affirmed the denial of habeas relief.
Court Description: Habeas Corpus. The panel affirmed the district court’s denial of a California state prisoner’s habeas corpus petition challenging his conviction by jury trial for second-degree murder. The panel held that under Brady v. Maryland, the prosecution concealed evidence that could have bolstered the petitioner’s self-defense claim, but this error did not sufficiently prejudice the defense to warrant habeas corpus relief. The panel also held that there was no error under the Antiterrorism and Effective Death Penalty Act in the state court’s rejection of a Napue claim of a violation of due process in the presentation of false testimony.
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