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Faria v. Lord
1:04-cv-02411
| E.D.N.Y | Sep 2, 2012
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Background

  • 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)
Read the full case

Case Details

Case Name: Faria v. Lord
Court Name: District Court, E.D. New York
Date Published: Sep 2, 2012
Docket Number: 1:04-cv-02411
Court Abbreviation: E.D.N.Y