Keith Smith v. Noah Nagy
962 F.3d 192
6th Cir.2020Background
- Victim Annette Ralston found stabbed and beaten in her Detroit home; no physical evidence linked Keith Smith to the crime.
- Two acquaintances (Shayne Dennis and Latoya Evans) testified at trial that Smith confessed to killing a woman while attempting to rob a safe; housemate and victim’s son placed Smith at the house the night before.
- Jury convicted Smith of first‑degree felony murder and assault with intent to commit armed robbery; acquitted on premeditated murder; sentenced to life without parole for felony murder.
- After trial, a juror reported that some jurors changed votes to guilty because they believed felony murder carried a light sentence; Smith requested a Remmer hearing/new trial and was denied by the trial court and on appeal.
- Postconviction, an affidavit by Robert Evans (brother of Latoya Evans) recanted or undermined the confession testimony; state courts declined to grant a new trial on procedural grounds; Smith pursued federal habeas relief and appealed the denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Smith was entitled to a Remmer hearing on juror bias/extraneous influence | Smith: jurors changed votes after being informed about light sentence for felony murder; this is a colorable extraneous influence requiring a hearing | Warden: no allegation that information came from an outside source; jurors’ sentencing beliefs are internal and not Remmer material | Court: affirmed state court — absent an allegation that the sentence information came from an external source, no Remmer hearing was required (jury’s sentencing beliefs could be internal) |
| Sufficiency of the evidence for felony murder and assault | Smith: evidence was insufficient — no physical link, no safe, no value taken, confession testimony unreliable | Warden: circumstantial evidence (confession testimony plus presence at house) permits reasonable inference of guilt; credibility for jury to decide | Court: affirmed — viewing evidence in prosecution’s favor, a rational juror could convict; appellate court’s conclusion was not unreasonable under AEDPA |
| Whether Robert Evans’s affidavit supports a freestanding actual‑innocence claim | Smith: affidavit undermines key witnesses and establishes actual innocence or at least warrants review | Warden: affidavit-based claim is untimely/procedure-barred and insufficient as a freestanding basis for relief | Court: treated the affidavit as a freestanding actual‑innocence claim and rejected it — even if cognizable, affidavit does not affirmatively prove Smith probably innocent |
Key Cases Cited
- Remmer v. United States, 347 U.S. 227 (1954) (trial court must hold a hearing when juror bias from extraneous influence is alleged)
- Turner v. Louisiana, 379 U.S. 466 (1965) (jury verdict must be based on evidence developed at trial)
- Irvin v. Dowd, 366 U.S. 717 (1961) (impartial jury standard)
- Smith v. Phillips, 455 U.S. 209 (1982) (Remmer hearing is remedy for allegations of juror partiality)
- Tanner v. United States, 483 U.S. 107 (1987) (distinguishes internal juror influences from external ones for impeachment purposes)
- Warger v. Shauers, 574 U.S. 40 (2014) (no‑impeachment rule bars testimony about juror deliberations except for specified external influences)
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)
- In re Winship, 397 U.S. 358 (1970) (prosecution must prove every element beyond a reasonable doubt)
- Williams v. Taylor, 529 U.S. 362 (2000) (AEDPA standard for federal habeas review of state court decisions)
- Harrington v. Richter, 562 U.S. 86 (2011) (state court errors must be objectively unreasonable for habeas relief under AEDPA)
- Schlup v. Delo, 513 U.S. 298 (1995) (actual‑innocence gateway standard is procedural, not an independent basis for relief)
- Herrera v. Collins, 506 U.S. 390 (1993) (discusses freestanding actual‑innocence claims and high burden to obtain relief)
- Peña‑Rodriguez v. Colorado, 580 U.S. 206 (2017) (racial‑bias statements by jurors are an exception to the no‑impeachment rule)
- Fullwood v. Lee, 290 F.3d 663 (4th Cir. 2002) (distinguishes external information that jurors could not have brought to deliberations from general knowledge)