Carter v. Woods, 2:16-cv-10590

Petitioner Willie James Carter was convicted by a jury in Wayne County of first‑degree murder for stabbing Tarrance Talley to death during/after a fistfight; sentenced to life without parole.
Eyewitnesses described Talley (much larger) initiating a fight, Carter being beaten, then stabbing Talley multiple times after Talley collapsed; Browen testified Carter said he was "about to kill" Talley and continued stabbing and kicking him.
Defense presented medical records and a scene investigator; Browen initially unavailable but later called as a rebuttal witness and testified to events unfavorable to Carter; Carter waived testifying twice.
At trial Carter rejected a prosecutor offer to plead to second‑degree murder (15–30 years) after consulting counsel and family; he confirmed on the record the rejection was voluntary and informed.
On direct appeal Carter raised: improper admission of rebuttal evidence, insufficient evidence of premeditation/deliberation, and ineffective assistance of counsel for advising rejection of the plea; Michigan courts rejected all claims and the Michigan Supreme Court denied review.
Carter filed a 28 U.S.C. § 2254 habeas petition in federal court; the district court denied the petition, denied a certificate of appealability, and denied leave to appeal in forma pauperis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of rebuttal evidence	Browen's rebuttal testimony was not responsive to defense and violated due process	No clearly established Supreme Court rule prohibits calling a witness in rebuttal; Carter had opportunity to cross and respond	Denied — state court ruling not contrary to or an unreasonable application of Supreme Court law; trial was fundamentally fair
Sufficiency of evidence for premeditation	Evidence showed fight began unexpectedly and Carter acted in self‑defense, so no premeditation/deliberation	Evidence (multiple stab wounds, follow‑up stabbing after collapse, statements to kill) permitted a rational jury to find premeditation/deliberation	Denied — Jackson standard satisfied; rational juror could find premeditation/deliberation
Ineffective assistance for plea advice	Counsel (later disbarred) advised rejecting plea for pecuniary reasons; counsel's advice caused rejection of plea	Record shows counsel requested a plea offer, Carter consulted counsel and family, was questioned under oath and voluntarily rejected the offer	Denied — Strickland/Lafler not satisfied; no reasonable probability Carter would have accepted plea absent counsel's conduct
Certificate of Appealability	N/A	N/A	Denied — reasonable jurists would not debate the court's resolution

Taylor v. Illinois, 484 U.S. 400 (1988) (addresses preclusion of defense witnesses for discovery violations)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)
Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong ineffective assistance test)
Lafler v. Cooper, 566 U.S. 156 (2012) (prejudice analysis when counsel’s advice leads defendant to reject plea)
Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA deference; limits on federal habeas relief)
Wiggins v. Smith, 539 U.S. 510 (2003) (unreasonable application prong under AEDPA)
Mitchell v. Esparza, 540 U.S. 12 (2003) (definition of "contrary to" precedent under AEDPA)
Williams v. Taylor, 529 U.S. 362 (2000) (standards for "contrary to" and "unreasonable application" under AEDPA)
Carey v. Musladin, 549 U.S. 70 (2006) (definition of "clearly established" Supreme Court law under AEDPA)