Karim Eley v. Charles Erickson, 2013 U.S. App. LEXIS 7118

Karim Eley, a Pennsylvania prisoner, seeks federal habeas relief under AEDPA after a state jury convicted him of second-degree murder, robbery, and conspiracy to commit robbery for a July 2000 Harrisburg taxi-cab crime.
Eley was tried jointly with Lester Eiland and Edward Mitchell; three successive juries resulted in a conviction at the third trial.
Evidence included eyewitness accounts, crime-scene findings, and post-arrest statements; the Commonwealth introduced extrajudicial confessions by co-defendants who did not testify.
Two pretrial trials ended in mistrials; Eley was acquitted of conspiracy to murder but convicted of the remaining charges, with life imprisonment for murder.
The District Court denied the petition; the Third Circuit granted a certificate of appealability and ultimately reversed in part, granting relief on Bruton but not on Jackson, and remanding for retrial or release within 120 days.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence under Jackson v. Virginia	Eley argues evidence was insufficient to prove guilt beyond a reasonable doubt.	Commonwealth contends the evidence, viewed in the light favoring the prosecution, supported all elements.	No relief on the Jackson claim; state-court conviction supported by substantial evidence under AEDPA standard.
Bruton/Confrontation Clause and non-testifying co-defendants’ statements	Eley asserts Bruton/ Richardson/Gray violations from admitted co-defendant confessions.	Commonwealth claims redaction and limiting instructions preserved the defendants’ rights.	Habeas relief granted on Bruton claim; remand for retrial within 120 days or release; Bruton error found to be not harmless.
Limiting instructions for contextual implications under Richardson/Gray	Instructions were inadequate to prevent inference that Eley was implicated by co-defendant confessions.	Jury instructions plus redaction complied with governing precedents.	Ohio? (mid-text indicates finding of unreasonable application of Bruton/Gray; further analysis not reached due to Bruton relief)
Reasonable doubt instruction under Boyde v. California	Challenge that the jury instruction lowered the burden of proof.	Instruction did not meaningfully affect the burden when properly considered.	Claim not decided because Bruton relief requires remand; Boyde claim left undecided.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (established standard for sufficiency of evidence to sustain a conviction)
Bruton v. United States, 391 U.S. 123 (U.S. 1968) (non-testifying co-defendant statements cannot be used to implicate another defendant at a joint trial)
Richardson v. Marsh, 481 U.S. 200 (U.S. 1987) (redaction limits on co-defendant statements; context matters for Bruton-type issues)
Gray v. Maryland, 523 U.S. 185 (U.S. 1998) (expands Bruton to redactions that facially implicate the defendant)
Coleman v. Johnson, 132 S. Ct. 2060 (U.S. 2012 (per curiam)) (reaffirms deference to jury’s role; Coleman affecting Jackson-based review)
Delli Paoli v. United States, 352 U.S. 232 (U.S. 1957) (limiting instruction standard prior to Bruton; referenced in Richardson context)
Vazquez v. Wilson, 550 F.3d 270 (3d Cir. 2008) (discussed Bruton redaction and contextual implications; precedential for Bruton analysis)
Travers v. Commonwealth, 764 Pa. 362 (Pa. 2001) (Pa. Supreme Court decision cited regarding redaction language in Bruton contexts)