Eddie Williams v. Superintendent Greene SCI, 112 F.4th 155

Background

Eddie Williams was convicted in Pennsylvania for crimes stemming from a drug dispute, including first-degree murder and related offenses.
At his joint trial, the judge read a non-testifying co-defendant (Rick Cannon)'s entire Criminal Information—including counts naming Williams as a coconspirator—twice to the jury.
Williams’s defense counsel did not object to this reading, and in fact opened the door by referencing Cannon’s plea in opening remarks, then failed to seek redaction or limiting instructions.
On appeal, Williams claimed his Sixth Amendment rights under the Confrontation Clause were violated and asserted ineffective assistance of counsel (IAC).
State courts denied Williams relief, but the federal district court granted habeas relief, which the Commonwealth appealed.
The Third Circuit reviewed the federal habeas grant de novo, focusing on whether the reading violated Bruton and Strickland standards.

Issues

Issue	Williams's Argument	Commonwealth's Argument	Held
Whether reading Cannon’s Criminal Information violated the Confrontation Clause	The reading was testimonial, akin to a plea allocution/confession, and implicated Williams without opportunity for cross-examination	The document was not testimonial; no Confrontation Clause violation because it was not created for trial	The Criminal Information was testimonial; admission violated the Confrontation Clause under Bruton and Crawford
Whether Williams’s trial counsel was constitutionally ineffective	Counsel’s failure to object or request redaction/limiting instructions was objectively unreasonable and prejudicial	Counsel could have had a strategic reason; no prejudice given other trial evidence	Counsel’s representation was deficient and prejudicial under Strickland; IAC established
Whether state court's denial was contrary to or unreasonable application of federal law	State courts applied wrong standards and failed to recognize clear Sup. Ct. precedent	State courts reasonably applied Strickland and Confrontation Clause law	State courts unreasonably applied and misapplied federal law; habeas relief proper
Whether the erroneous evidence had a 'substantial and injurious effect' on the verdict	Yes, the jury relied on Cannon’s plea; jury’s request to rehear Criminal Information showed reliance	No, sufficient incriminating evidence existed regardless of the plea information	Substantial and injurious effect found given weaknesses in direct evidence and jury reliance

Key Cases Cited

Crawford v. Washington, 541 U.S. 36 (2004) (Confrontation Clause bars admission of testimonial hearsay without prior cross-examination)
Bruton v. United States, 391 U.S. 123 (1968) (Admission of a non-testifying codefendant’s confession implicating the accused violates the Confrontation Clause)
Strickland v. Washington, 466 U.S. 668 (1984) (Established standard for ineffective assistance of counsel: deficient performance and prejudice)
Richardson v. Marsh, 481 U.S. 200 (1987) (Redacted confessions that remove reference to co-defendant may avoid Bruton error)
Harrington v. Richter, 562 U.S. 86 (2011) (Federal habeas relief only if state court decision was contrary to or an unreasonable application of Supreme Court precedent)
Brecht v. Abrahamson, 507 U.S. 619 (1993) (Under habeas, relief requires showing error had substantial and injurious effect)