Faria v. Lord
1:04-cv-02411
| E.D.N.Y | Sep 2, 2012Background
- Petitioner Leah Faria was convicted of depraved-indifference murder and related offenses in New York Supreme Court, Queens County, after a trial in May 2000.
- She received an aggregate sentence of 21.5 years to life for murder, plus concurrent and consecutive terms for weapon and evidence-tampering offenses.
- She appealed unsuccessfully in state court; she then filed a timely federal habeas corpus petition under 28 U.S.C. § 2254 in 2004.
- Key trial evidence included eyewitness testimony, forensic testimony, and Petitioner’s recorded statements admitting the shooting in a basement of the LeFrak City complex.
- A central factual dispute concerned the adequacy of disclosure of a taped interview of a key witness (Summerville) and the impact on trial proceedings.
- The court applied AEDPA review and denied relief on all claims, concluding the state court’s decision was not contrary to or an unreasonable application of federal law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rosario/Brady disclosure delay | Faria contends delayed disclosure prejudiced trial. | State argues Rosario is state-law; Brady claim requires materiality and prejudice. | No federal violation; no prejudice; relief denied. |
| Sleeping juror claim | Sleeping juror prejudiced the defense. | No credible evidence of misconduct; defense consented to retention. | No prejudice; claim rejected. |
| Sufficiency of the evidence | Evidence does not support depraved-indifference murder; could be only manslaughter. | Evidence showed depraved indifference beyond a reasonable doubt. | Evidence was sufficient; conviction sustained. |
| Excessive sentence | Sentence excessive given lack of prior offenses. | Sentence fell within state-law statutory limits. | No federal due-process violation; affirmed. |
Key Cases Cited
- Rodriguez v. People, N.Y.2d 286 (1961) (Rosario rule—state-law disclosure; not federal constitutional issue)
- Brady v. Maryland, 373 U.S. 83 (1963) (federal due-process duty to disclose exculpatory evidence)
- Strickler v. Greene, 527 U.S. 263 (1999) (materiality and prejudice in Brady claims)
- Bagley v. United States, 473 U.S. 667 (1985) (prejudice standard for suppression of evidence)
- Williams v. Taylor, 529 U.S. 362 (2000) (AEDPA deference; clearly established federal law)
- Sellan v. Kuhlman, 261 F.3d 303 (2001) (state-court adjudication of federal claims; deferential review)
- Jones v. Stinson, 229 F.3d 112 (2000) (standard for assessing state-court decisions under AEDPA)
- United States v. Wainwright, 469 U.S. 412 (1985) (trial courts’ discretion in handling juror issues)
- Irvin v. Dowd, 366 U.S. 717 (1961) (prejudice from juror misconduct must be shown)
- Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency of evidence standard for federal review)
