Danski v. Campbell
2:21-cv-12409
E.D. Mich.Mar 11, 2025Background
- Jordan Christopher Danski was convicted in Michigan state court of first-degree home invasion and unlawfully driving away an automobile after a 2015 home invasion in Sterling Heights, Michigan.
- Evidence against Danski included cell phone tower data tracking his movements, his fingerprints on stolen property, eyewitnesses placing him at the scene, and his statement during police questioning referencing the home invasion before being informed of it.
- At trial, Danski's defense involved alternate suspect testimony and cell phone evidence challenges; he also attempted to provide alibi witnesses, but their probative value was disputed and their testimony was not clearly exculpatory.
- Danski's post-conviction relief efforts in state courts raised claims of ineffective counsel, improper jury instructions, and insufficient evidence; all were rejected at various levels, with some claims held procedurally defaulted.
- In federal habeas, Danski claimed improper jury instructions, insufficient evidence, ineffective counsel (for failing to use or challenge expert testimony/alibi witnesses), and unconstitutional sentencing for maintaining innocence.
Issues
| Issue | Danski's Argument | State's Argument | Held |
|---|---|---|---|
| Supplemental jury instruction | Aiding/abetting instruction during deliberations denied due process and jury trial. | Instruction matched charges, evidence, and gave adequate notice. | No violation; instruction proper under Supreme Court law. |
| Sufficiency of the evidence | Evidence (cell data, fingerprints, witness ID) was insufficient for conviction. | Both direct and circumstantial evidence support a rational verdict. | Evidence was sufficient; habeas relief denied. |
| Ineffective assistance of counsel | Counsel failed to call alibi witnesses, challenge/provide expert, or object at trial. | Counsel's trial strategy was reasonable; witness testimony unhelpful. | No deficient performance or prejudice shown; relief denied. |
| Sentencing for maintaining innocence | Sentenced more harshly for exercising right to remain silent/post-trial innocence. | Sentence based on criminal history, not lack of remorse/silence. | No constitutional error; consideration of remorse allowed. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (standard for ineffective assistance of counsel claims)
- Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency of the evidence standard in criminal cases)
- Estelle v. McGuire, 502 U.S. 62 (limits habeas relief to errors affecting due process)
- Cupp v. Naughten, 414 U.S. 141 (habeas relief for jury instructions requires showing of due process violation)
- Williams v. Taylor, 529 U.S. 362 (defines "contrary to" and "unreasonable application" of federal law under AEDPA)
- Harrington v. Richter, 562 U.S. 86 (sets "doubly deferential" standard for federal habeas review of state court decisions)
- Mitchell v. United States, 526 U.S. 314 (addressed sentencing phase Fifth Amendment rights)
- Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (expert witness reliability standard)
