922 F.3d 737
6th Cir.2019Background
- Edmonds and Hall were codefendants convicted in state court of murdering a homeless man; their joint state appeals failed.
- Hall filed a federal habeas petition under 28 U.S.C. § 2254; the district court denied relief and this Court affirmed.
- Edmonds later filed his own § 2254 petition raising four overlapping claims previously presented in the codefendants’ appeals/habeas proceedings.
- The district court dismissed four of Edmonds’s claims on the ground that the law-of-the-case doctrine barred relitigation because Hall’s habeas action had rejected similar claims.
- The Sixth Circuit reviewed whether the law-of-the-case doctrine can bind a separate habeas petitioner who was a codefendant and held it cannot; the court reversed and remanded for merits review with the full state-court record.
- The panel instructed the district court on standards of review to apply: AEDPA deference for voir dire and for-cause-strike claims, de novo review for the Milligan-hearsay exclusion claim, and left the standard for the victim-impact testimony claim to the district court.
Issues
| Issue | Plaintiff's Argument (Edmonds) | Defendant's Argument (State) | Held |
|---|---|---|---|
| 1) Admission of victim‑impact testimony by a hospital victim advocate | Testimony was prejudicial and violated due process; denied a fair trial | Law-of-the-case (Hall’s prior denial) bars relitigation | Law-of-the-case does not apply across separate habeas petitions; claim remanded for merits |
| 2) Exclusion of non‑testifying eyewitness Milligan’s hearsay statements | Excluding Milligan’s exculpatory hearsay denied right to present a complete defense | Prior adverse ruling in Hall’s habeas controls | Law-of-the-case inapplicable here; claim remanded for merits; court directed de novo review |
| 3) Restrictions on voir dire (time limits, curtailed mitigation/race questioning, banning leading questions) | Restrictions violated right to an impartial jury and impaired trial defense | Hall’s prior habeas resolution forecloses relitigation | Law-of-the-case does not bind separate habeas petition; claim remanded; AEDPA review applies |
| 4) Refusal to strike two jurors for cause | Denial of for‑cause strikes violated impartial jury right | Preclusive effect of Hall’s habeas decision bars challenge | Law-of-the-case inapplicable; remanded for merits; AEDPA review applies |
Key Cases Cited
- Christianson v. Colt Indus. Operating Corp., 486 U.S. 800 (1988) (defines law‑of‑the‑case as intra‑case doctrine)
- Pennsylvania v. Finley, 481 U.S. 551 (1987) (post‑conviction habeas is a separate civil case)
- Taylor v. Sturgell, 553 U.S. 880 (2008) (nonparties generally lack claim/issue preclusion; need own day in court)
- Burley v. Gagacki, 834 F.3d 606 (6th Cir. 2016) (discusses purpose and scope of law‑of‑the‑case)
- United States v. Lawrence, 179 F.3d 343 (5th Cir. 1999) (post‑conviction motions by codefendants are separate; law‑of‑the‑case not binding across them)