Hamilton v. Lee, 707 F. App'x 12

Background

Rohan Hamilton was convicted in New York state court; he sought federal habeas relief under 28 U.S.C. § 2254 challenging (1) Confrontation Clause violations relating to fingerprint/palm-print evidence and (2) ineffective assistance of trial counsel for not calling a defense fingerprint expert.
The New York Appellate Division found Hamilton’s Confrontation Clause claims unpreserved under the contemporaneous objection rule and, alternatively, without merit; it denied the ineffective-assistance claim on the merits.
The district court denied habeas relief; granted a certificate of appealability on confrontation and ineffective-assistance claims; Hamilton appealed to the Second Circuit.
The Second Circuit reviewed the district court de novo (factual findings for clear error) under AEDPA standards, requiring that state-court decisions not be overturned unless contrary to or an unreasonable application of Supreme Court precedent or based on unreasonable factual determinations.
The court held Hamilton’s Confrontation Clause claims were procedurally barred (failure to object on Confrontation Clause grounds at trial) and, alternatively, that there was no Confrontation Clause violation because Hamilton had the opportunity to cross-examine the relevant witnesses.
The court also affirmed rejection of the ineffective-assistance claim: counsel’s decision not to call a defense fingerprint expert was a reasonable strategic choice and, in any event, Hamilton failed to show prejudice given the overall strength of the evidence.

Issues

Issue	Hamilton's Argument	Lee's Argument	Held
Whether Confrontation Clause claim preserved	Hamilton argued hearsay objection sufficed to preserve Confrontation claim	Lee argued Hamilton failed to preserve Confrontation claim under NY contemporaneous-objection rule	Not preserved; procedurally barred (independent and adequate state rule)
Whether Confrontation Clause violated on the merits	Hamilton argued admission of fingerprint-related testimony violated Crawford	Lee argued Hamilton had opportunity to cross-examine declarants and thus no Crawford violation	On merits (alternative): no violation—Hamilton had opportunity to cross-examine witnesses
Whether trial counsel was ineffective for not calling defense fingerprint expert	Hamilton argued counsel’s failure was deficient and prejudicial	Lee argued strategic choice, cross-examination adequate, and no prejudice given strong evidence	Denied: counsel’s choice reasonable; no Strickland prejudice shown
Whether AEDPA/Strickland standards were met to grant habeas relief	Hamilton argued state-court rulings unreasonably applied federal law	Lee argued state rulings reasonably applied Supreme Court precedent and facts	Affirmed: state decisions were not unreasonable under AEDPA/Strickland

Key Cases Cited

Ponnapula v. Spitzer, 297 F.3d 172 (2d Cir. 2002) (standard of review for § 2254 denials)
Coleman v. Thompson, 501 U.S. 722 (1991) (cause-and-prejudice rule for procedural default)
Crawford v. Washington, 541 U.S. 36 (2004) (Confrontation Clause testimonial-statement rule)
Strickland v. Washington, 466 U.S. 668 (1984) (ineffective-assistance two-prong test)
Harrington v. Richter, 562 U.S. 86 (2011) (deference to trial strategy; no per-se requirement to call experts)
Zarvela v. Artuz, 364 F.3d 415 (2d Cir. 2004) (state-court adjudication on merits counts for AEDPA)
Cotto v. Herbert, 331 F.3d 217 (2d Cir. 2003) (independence of state procedural bars)
Garcia v. Lewis, 188 F.3d 71 (2d Cir. 1999) (New York contemporaneous-objection rule explained)
Richardson v. Greene, 497 F.3d 212 (2d Cir. 2007) (adequacy of NY preservation rule)
Bennett v. United States, 663 F.3d 71 (2d Cir. 2011) (recitation of Strickland standard)
Lindstadt v. Keane, 239 F.3d 191 (2d Cir. 2001) (overwhelming evidence can defeat prejudice prong under Strickland)