Jaynes v. Mitchell, 824 F.3d 187

Background

In 1997-1998 Charles Jaynes befriended ten-year-old Jeffrey Curley, who later disappeared; Curley’s body was found in a gasoline-soaked plastic container with concrete and lime; cause of death was gasoline inhalation.
Police arrested Jaynes after receiving evidence from co-defendant Sicari; items (duct tape, receipts, license with Jaynes’s photo but different name) were found in Jaynes’s impounded Cadillac and, following a warrant, in Jaynes’s New Hampshire apartment.
Jaynes was convicted in Massachusetts of kidnapping and second-degree murder; the Massachusetts Appeals Court (MAC) affirmed (Commonwealth v. Jaynes, 770 N.E.2d 483) and the SJC denied further review.
A second postconviction motion and appeal (challenging evidentiary rulings, suppression issues, and counsel performance) were denied by the MAC.
Jaynes filed a federal habeas petition under 28 U.S.C. § 2254 raising five claims (jurisdiction instruction/Winship, courtroom closures/public trial, admission of inflammatory evidence/due process, ineffective assistance of trial counsel, ineffective assistance of appellate counsel); the district court dismissed the petition and the First Circuit affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction instruction / Winship (whether jury had to find fatal injury occurred in MA)	Jaynes: trial judge should have instructed jury that the Commonwealth must prove the fatal violence/injury occurred in Massachusetts.	Commonwealth: claim not exhausted in state courts; MAC did not err under state law and evidence established fatal acts occurred in MA.	Claim unexhausted; even on merits state-court findings would satisfy any jury requirement, so no habeas relief.
Public-trial right / courtroom closures during voir dire	Jaynes: brief closures violated Sixth Amendment right to public trial.	Commonwealth: closures were narrowly tailored, on request of individual venirepersons, and only during sensitive questioning; judge articulated basis.	No Waller violation; MAC’s application of Waller reasonable.
Admission of prejudicial evidence (pedophilia-related writings, NAMBLA, witness label)	Jaynes: evidence was irrelevant and overwhelmingly prejudicial, denying due process.	Commonwealth: evidence relevant to motive, intent, and method; limiting instructions were given; prejudicial effect not so inflammatory as to make trial fundamentally unfair.	No due-process violation; evidentiary rulings did not render trial fundamentally unfair.
Ineffective assistance of trial counsel (failure to move to suppress vehicle/apartment evidence; failure to request instruction/object to closures)	Jaynes: counsel deficient for not suppressing inventory-search fruits, not seeking jurisdiction instruction, and not objecting to closures.	Commonwealth: impoundment/inventory search and the apartment warrant were supported by common-sense bases and probable cause; any failure to litigate these points was not prejudicial.	Under Strickland (and doubly deferential AEDPA review), MAC reasonably concluded no deficient performance or prejudice.
Ineffective assistance of appellate counsel (failure to raise trial counsel/ evidentiary claims)	Jaynes: appellate counsel should have raised additional issues that could have changed outcome.	Commonwealth: appellate omissions would not have produced a different result; underlying claims lack merit.	MAC reasonably denied relief; habeas relief not warranted.

Key Cases Cited

Scott v. Gelb, 810 F.3d 94 (1st Cir.) (standard of appellate review on habeas).
In re Winship, 397 U.S. 358 (1970) (beyond a reasonable doubt requirement for elements of crime).
Baldwin v. Reese, 541 U.S. 27 (2004) (exhaustion requires fair presentation of federal claim to state courts).
Waller v. Georgia, 467 U.S. 39 (1984) (standards for closing proceedings to the public).
Strickland v. Washington, 466 U.S. 668 (1984) (ineffective-assistance-of-counsel test).
Whren v. United States, 517 U.S. 806 (1996) (inventory-search justification and police practices).
Cullen v. Pinholster, 563 U.S. 170 (2011) (limits on evidentiary hearings when state record precludes § 2254 relief).
Jaynes (Commonwealth v. Jaynes), 770 N.E.2d 483 (Mass. App. Ct.) (state appellate decision addressing jurisdictional and evidentiary issues).