Linton v. Saba
2016 U.S. App. LEXIS 1685
| 1st Cir. | 2016Background
- Linton killed Andrea Harvey in Cambridge; Harvey’s body was found Feb. 24, 2005, after Linton had left for North Carolina following a Feb. 22–23 dispute with Harvey.
- Evidence at trial showed Harvey died by manual strangulation with extensive injuries, and the apartment had no forced entry, with Linton holding keys and having access.
- Linton had a February 2005 affair with Latricia Carter; he gave conflicting timelines about his whereabouts and claimed concerns Harvey would harm herself.
- A court-ordered medical examiner linked the death to a prolonged strangulation, with an estimated time frame of death prior to Feb. 24, 2005.
- Massachusetts trial court convicted Linton of first-degree murder under the extreme atrocity or cruelty theory; the SJC affirmed, applying Cunneen factors and Jackson/V. Virginia standards for sufficiency of evidence.
- The district court denied habeas relief; on appeal, the First Circuit affirmed AEDPA deference to the state court’s decision and rejected both the sufficiency and Confrontation Clause challenges.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence for first-degree murder | Linton argues insufficient evidence | Commonwealth asserts sufficient circumstantial evidence | No; evidence supports identity, opportunity, motive, and conduct under Cunneen. |
| Confrontation Clause challenge to Harvey's statements to her father | Harvey's statement was testimonial and violated confrontation rights | Statement non-testimonial under excited-utterance/primary purpose analysis | No; SJC reasonably found non-testimonial; AEDPA deferential review upheld. |
| Application of Jackson standard (Latimore vs Jackson) | SJC misapplied the federal standard | Latimore is functionally equivalent to Jackson for AEDPA review | No; district court correctly applied deference; Latimore standard aligns with Jackson. |
| AEDPA deference standards | State court decision unreasonable under AEDPA | State court’s decision reasonable under AEDPA standards | No; the SJC’s decision was not contrary to or an unreasonable application of clearly established federal law. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for federal habeas review: rational trier could find guilt beyond a reasonable doubt)
- Cunneen, 449 N.E.2d 658 (Mass. 1989) (Seven Cunneen factors for extreme cruelty/motivation in murder)
- Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (testimonial statements and Confrontation Clause scope)
- Davis v. Washington, 547 U.S. 813 (U.S. 2006) (confrontation analysis in non-testimonial vs testimonial contexts)
- Commonwealth v. Latimore, 824 N.E.2d 821 (Mass. 2005) (Mass. standard consistent with Jackson for sufficiency review)
- Commonwealth v. Nesbitt, 892 N.E.2d 299 (Mass. 2008) (two-step state approach to Confrontation Clause)