Arthur Grajeda v. A. Scribner
541 F. App'x 776
9th Cir.2013Background
- Grajeda was charged in California state court with two counts of murder jointly with a codefendant; the trial court denied Grajeda's motion to sever his trial from the codefendant's.
- Grajeda was convicted on both counts; the California Court of Appeal affirmed, with one judge dissenting; the California Supreme Court denied review without comment.
- This court reviews the district court's habeas denial de novo and factual findings for clear error, applying AEDPA standards.
- The Court reviews the last reasoned state judgment addressing the severance claim per Ylst v. Nunnemaker.
- Under AEDPA, relief is granted only if the state court decision was contrary to or unreasonably applied clearly established federal law, or based on unreasonable factual determinations.
- The district court's decision and the California Court of Appeal's ruling were found not to be contrary to or an unreasonable application of clearly established federal law; the petition was denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of severance violated federal law | Grajeda argues severance was required under controlling precedent. | State contends no constitutional error from the denial. | No constitutional violation; AEDPA standard not met; affirmed. |
| Whether cross-admissibility of the co-defendant's evidence against Grajeda violated due process | Grajeda contends cross-admissibility was improper under governing precedents. | State maintains cross-admissibility was permissible under applicable law and standards. | California Court of Appeal's cross-admissibility finding not contrary to clearly established federal law; affirmed. |
Key Cases Cited
- Zafiro v. United States, 506 U.S. 534 (1993) (joinder and severance do not by themselves violate the Constitution)
- United States v. Lane, 474 U.S. 438 (1986) (misjoinder; standards for severance considerations)
- Collins v. Runnels, 603 F.3d 1127 (9th Cir. 2010) (neither Zafiro nor Lane set binding constitutional standard on states)
- Runningeagle v. Ryan, 686 F.3d 758 (9th Cir. 2012) (reiterates Collins; neither decision is clearly established federal law for § 2254)
- Harrington v. Richter, 131 S. Ct. 770 (2011) (habeas standard: relief only for unreasonable application of clearly established law)
- Ylst v. Nunnemaker, 501 U.S. 797 (1991) (law on finality of last reasoned state judgment for federal review)
- Carrera v. Ayers, 699 F.3d 1104 (9th Cir. 2012) (reaffirmation of AEDPA review framework in Ninth Circuit)