Mario Collier v. Blaine Lafler, 419 F. App'x 555

Collier was convicted of first-degree murder in Michigan and sentenced to life imprisonment.
After exhausting state appeals, Collier filed a federal habeas petition under 28 U.S.C. § 2254; the district court denied relief and granted a certificate of appealability on four issues.
Two eyewitnesses testified Collier’s driver’s seat was in the Bonneville from which the shots were fired; Collier’s brother testified he sat in the driver’s seat immediately before the murder.
The prosecution introduced flight-and-fight testimony showing Collier fleeing from police; Michigan law allowed such evidence as consciousness of guilt under state rules.
Thibodeaux, another eyewitness, disappeared prior to trial; the State did not produce him, and Collier argued this violated due process but the court found due diligence insufficient for relief.
The court analyzed under AEDPA deferential standards and affirmed the district court’s denial of habeas relief on all four issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Flight evidence due process issue	Collier argues flight evidence was prejudicial and violated due process	State argues evidence was peripheral and permissible to show consciousness of guilt	No due-process violation; evidence not materially undermining fair trial
Prosecution’s failure to produce witness	Thibodeaux’s non-production could create reasonable doubt	State exercised due diligence; AEDPA review limits relief	No relief; due-diligence issue outside AEDPA scope; not conclusively exculpatory
Ineffective assistance of counsel	Trial/appellate counsel failed to object and present certain evidence	No deficient performance or prejudice under Strickland; tactical decisions valid	No ineffective-assistance claim established under Strickland
Sufficiency of the evidence	Evidence insufficient to prove he fired the gun or premeditation	Evidence showed Collier drove the car and eyewitness testimony supported guilt	Evidence sufficient for a rational trier of fact to convict under Michigan law

Wong Sun v. United States, 371 U.S. 471 (Supreme Court 1963) (acknowledges limits on prejudice of certain evidence; flight evidence discussed in context of due process)
Chambers v. Mississippi, 410 U.S. 284 (Supreme Court 1973) (trial errors cannot defeat due process; admissibility of evidence analyzed under fundamental fairness)
Estelle v. McGuire, 502 U.S. 62 (Supreme Court 1991) (limits on admissible evidence; prior bad acts evidence generally permissible within state rules)
Brown v. O’Dea, 227 F.3d 642 (6th Cir. 2000) (prejudice and materiality of prejudicial evidence considered in due-process analysis)
Maldonado v. Wilson, 416 F.3d 470 (6th Cir. 2005) (due-process standards for prejudicial evidence without Supreme Court precedent on specific type of evidence)
Bugh v. Mitchell, 329 F.3d 496 (6th Cir. 2003) (propensity evidence and due-process limitations described; flight evidence context)