Crystal Keith v. Deanne Schaub
772 F.3d 451
7th Cir.2014Background
- Crystal Keith, caretaker of a 13-month-old (Christopher), was convicted of reckless homicide after admitting in a videotaped interview that she abused Christopher and another child (C.T.), and called 911 saying she had "just killed a baby."
- Psychiatrist/psychologist Michael Kula diagnosed Keith with multiple disorders and testified to diagnoses and IQ but was barred from testifying about Keith’s mental state on the day of the offense or opining about how her childhood abuse affected that state.
- The state trial court excluded parts of Kula’s proffered testimony under Wisconsin precedent (the Steele–Flattum/Morgan line), which limits expert opinion about a defendant’s capacity or intent when based on the defendant’s mental-health history.
- Keith filed a petition for federal habeas relief under 28 U.S.C. §2254, arguing the state courts’ exclusion violated her federal right to present a defense.
- The district court denied the petition; the Seventh Circuit affirmed, holding the state-court decision was not contrary to or an unreasonable application of clearly established federal law and that Keith received a fundamentally fair trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether exclusion of expert testimony about Keith’s history and mental state violated the right to present a defense | Keith: exclusion prevented presentation of evidence explaining her state of mind and causation for her actions | State: exclusion followed Wisconsin law limiting expert opinion on capacity/intent and excluded irrelevant history for general-intent offense | Held: No federal violation; state decision reasonable and §2254(d)(1) not satisfied |
| Whether Supreme Court clearly established a rule requiring admission of such expert evidence in non-capital trials | Keith: argued right-to-present-defense broadly requires admission | State: no controlling Supreme Court decision establishing Keith’s proposed rule | Held: No clearly established Supreme Court rule; §2254(d)(1) bars relief |
| Whether distinction between specific-intent and general-intent crimes makes expert testimony more admissible for general-intent crimes | Keith: claimed cases limiting expert testimony concern specific-intent offenses only | State: precedents and policy support limits on expert testimony about mental state regardless of intent category | Held: Court rejected Keith’s proposed distinction and found no basis to create one on collateral review |
| Whether trial was fundamentally fair given partial admission of Kula’s testimony | Keith: contended excluded testimony denied fair trial | State: most of Kula’s testimony was admitted; trial was fair | Held: Affirmed that Keith had a fundamentally fair trial; exclusion did not amount to constitutional error |
Key Cases Cited
- Bradshaw v. Richey, 546 U.S. 74 (describing limits on federal review of state-court interpretations of state law)
- Gilmore v. Taylor, 508 U.S. 333 (authority on limits to federal habeas relief concerning state-law evidentiary rulings)
- Estelle v. McGuire, 502 U.S. 62 (state evidentiary rulings generally not reviewable on federal habeas absent a distinct federal constitutional violation)
- Morgan v. Krenke, 232 F.3d 562 (7th Cir. 2000) (upholding Wisconsin limits on expert testimony about a defendant’s mental state)
- Nevada v. Jackson, 133 S. Ct. 1990 (2013) (prohibits framing habeas claims at too high a level of generality under §2254(d)(1))