Childers v. Floyd
2011 U.S. App. LEXIS 11162
| 11th Cir. | 2011Background
- Childers challenged Florida court rulings restricting cross-examination of the State’s key witness on bias/motive to lie.
- District Court denied habeas relief under AEDPA after determining the Florida appellate ruling was entitled to deference since it adjudicated the claim on the merits.
- Florida appellate court analyzed the Confrontation Clause claim under Florida Evidence Rule 90.403, not federal Confrontation Clause standards.
- Trial court allowed extensive cross-examination but excluded evidence regarding Elliot’s acquittal and the plea-revocation Notice of Revocation.
- Florida en banc court affirmed exclusion under Florida Rule 90.403 as balancing probative value against prejudice, citing concerns of jury confusion and unfair prejudice.
- Petitioner sought federal habeas relief; the Eleventh Circuit initially granted relief but, en banc, held AEDPA deferential review applied and affirmed denial
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Florida appellate ruling adjudicated the claim on the merits | Childers argues the Florida court mischaracterized the claim | Fla. contends ruling addressed Florida Rule 403 | Yes; court held adjudication on the merits under AEDPA |
| Whether exclusion of Elliot acquittal and Notice of Revocation violated Confrontation Clause | Childers contends ban deprived jury of motive evidence | State argues limits were permissible under Van Arsdall/403 | No; ruling not contrary to clearly established federal law under AEDPA |
| What standard of review applies to the Florida court’s cross-examination ruling under AEDPA | Deferential review to state court merited by AEDPA | Deferential review required; state court’s reasoning valid | Deferential AEDPA standard applies; decision not unreasonable under 28 U.S.C. §2254(d) |
Key Cases Cited
- Davis v. Alaska, 415 U.S. 308 (U.S. 1974) (bias, motive to lie is proper cross-examination focus)
- Delaware v. Van Arsdall, 475 U.S. 673 (U.S. 1986) (limits on cross-examination allowed to avoid prejudice; right to confrontation)
- Olden v. Kentucky, 488 U.S. 227 (U.S. 1988) (limits on cross-examination must not wholly preclude bias inquiry)
- Harrington v. Richter, 131 S. Ct. 770 (U.S. 2011) (establishes AEDPA deference presumption for adjudications on the merits)
- Rompilla v. Beard, 545 U.S. 374 (U.S. 2005) (requires de novo review when state court fails to address merits)
- Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (requires considering state court’s merits analysis in context of federal standard)