Patricia Conklin v. Molly Hill, 19-15310

Petitioner Patricia Conklin filed a federal habeas petition challenging trial counsel’s failure to object to the prosecutor’s motion to redact medical records at trial.
The redactions removed statements by Petitioner’s mother, Margarita Zelada, to medical staff that she had accidentally slipped and fallen rather than being pushed by Petitioner.
Trial counsel advanced a necessity defense: Petitioner pushed her mother to protect her from a stove fire caused by a malfunction.
The California Court of Appeal rejected the ineffective-assistance claim on direct appeal; the district court also denied habeas relief. The Ninth Circuit granted a COA on the objection issue.
AEDPA governs review; thus the question is whether the state court unreasonably applied Strickland v. Washington or unreasonably determined the facts.
The court found substantial evidence (Zelada’s multiple statements to law enforcement/medical personnel and Petitioner’s own statements/actions) supporting that Zelada had said Petitioner pushed her, making counsel’s tactical decision reasonable and any error non-prejudicial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel’s failure to object to redactions was deficient under Strickland	Conklin: counsel unreasonably failed to object to redactions that excluded exculpatory medical‑record statements	State/Prosecution: counsel reasonably refrained as objecting would have introduced statements inconsistent with the defense theory	Court: State court reasonably concluded non‑deficient tactical decision; AEDPA deference applies
Whether any deficiency prejudiced the defense (Strickland prong two)	Conklin: exclusion of Zelada’s accidental‑fall statements deprived her of a potentially different outcome	State/Prosecution: even if deficient, strong inculpatory evidence meant no reasonable probability of a different result	Court: State court reasonably concluded no prejudice; admission of other statements and admissions made different result unlikely

Strickland v. Washington, 466 U.S. 668 (establishes two‑part test for ineffective assistance: deficient performance and prejudice)
Harrington v. Richter, 562 U.S. 86 (explains AEDPA deference to state court applications of Strickland)
Yarborough v. Alvarado, 541 U.S. 652 (discusses fairminded jurists standard under AEDPA)
Woodford v. Garceau, 538 U.S. 202 (confirms AEDPA governs federal habeas review)
Murray v. Schriro, 882 F.3d 778 (9th Cir. 2018) (standard of review for district court denial of habeas)
Griffin v. Harrington, 727 F.3d 940 (9th Cir. 2013) (distinguished: counsel’s failure to object there lacked supporting tactical rationale)