Boylan 861802 v. Horton, 656 F.Supp.3d 743

In 2016 Boylan was convicted by a jury of first‑degree felony murder for the 2014 killing of Jacob Rameau and sentenced to life without parole. The killing occurred during a high‑speed chase after Boylan drove off in a stolen car and co‑defendant Gee shot Rameau.
In 2014 Boylan pleaded guilty to unlawfully driving away a vehicle (UDAA) and was sentenced; at that sentencing the court declined to score OV‑1 and OV‑2 (multiple‑offender/weapon points) after finding it was not a multiple‑offender case, but assessed OV‑3 (death/injury).
The State later charged Boylan with felony murder predicated on larceny/the theft of items from the stolen vehicle; at trial Boylan was convicted despite jury‑instruction and foreseeability issues noted on appeal.
On direct appeal Boylan alleged insufficient evidence and ineffective assistance (including failure to move to quash on res judicata/collateral estoppel grounds); the Michigan Court of Appeals rejected those claims without addressing factual findings made at the UDAA sentencing hearing.
On federal habeas review the magistrate judge concluded counsel was ineffective under Strickland for failing to file a motion to quash based on collateral estoppel rooted in the UDAA sentencing court’s factual finding that this was not a multiple‑offender case, and granted relief: Boylan’s felony‑murder conviction to be vacated unless the State seeks retrial within 90 days.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for failing to move to quash the felony‑murder information based on collateral estoppel from Boylan’s prior UDAA proceedings	Boylan: sentencing court’s finding that this was not a multiple‑offender case precludes relitigation of the same factual issue; counsel should have moved to quash	State: Boylan’s guilty plea to UDAA did not resolve larceny elements; res judicata/collateral estoppel do not bar the subsequent felony‑murder prosecution; appellate rejection was reasonable	Court: Counsel’s omission was objectively unreasonable and prejudicial; state court unreasonably applied Strickland by ignoring sentencing‑phase factual findings, warranting habeas relief on Ground II
Whether factual findings at a sentencing hearing can have preclusive effect against later prosecution	Boylan: sentencing findings (OV scoring dispute) were factual determinations that, if decided against the State by preponderance, could be preclusive under collateral estoppel	State: sentencing plea/adjudication did not determine larceny/co‑offender facts necessary to bar the later felony‑murder charge	Court: Sentencing facts can have preclusive effect; because the state appellate court failed to consider those sentencing findings, its Strickland analysis was unreasonable in this case

Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong ineffective assistance of counsel test)
Ashe v. Swenson, 397 U.S. 436 (1970) (criminal collateral estoppel / issue preclusion principle)
Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA deference and the double‑deference context for Strickland claims)
Cullen v. Pinholster, 563 U.S. 170 (2011) (habeas review generally limited to the state‑court record)
People v. Albers, 137 Mich. 678 (1904) (Michigan recognition of issue preclusion in criminal cases)