Robert Wilson v. Edward Sheldon, 874 F.3d 470

Background

In 1993 Brenda Navarre, a confidential informant, was fatally injured by blunt force trauma; a 110‑lb boulder at the scene was later destroyed after Toledo PD misclassified the offense as felonious assault and allowed evidence retention periods to lapse.
Robert Wilson was tried and convicted in 2008 for Navarre’s murder after his wife Janet Wilson (a confidential informant) and her son testified; Janet’s testimony was limited by spousal‑privilege and she received a Crime Stoppers payment.
Prior to trial, two officers (Sergeant Vasquez and Detective Beavers) testified that Janet’s trial testimony was consistent with her prior statements to them; the defense objected as hearsay.
Wilson sought access to Janet’s grand jury testimony; the trial court reviewed it in camera and denied production, finding sufficient non‑privileged testimony supported the indictment.
Wilson also argued the State violated due process by failing to preserve the boulder and other evidence; the evidence had been destroyed before the case was reclassified as a homicide.
On federal habeas under AEDPA, the district court denied relief; the Sixth Circuit affirmed, rejecting claims on prior consistent statements, grand jury transcript production (Brady), and failure to preserve evidence (Youngblood).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of officers’ testimony about Janet’s prior consistent statements	Wilson: officers’ testimony was hearsay and bolstered/impermissibly rehabilitated witness credibility, violating due process	State: testimony was non‑hearsay rehabilitation of credibility under state law and did not violate federal due process	Admission was not a federal due‑process violation; state courts reasonably applied law; no Supreme Court precedent showing constitutional error
Access to grand jury transcript (Brady/impeachment evidence)	Wilson: denial of grand jury transcript suppressed impeaching evidence in violation of Brady	State: grand jury secrecy; trial court reviewed transcript in camera and found no material impeachment; defendant never requested in state court	Court rejected Brady prejudice: no reasonable probability outcome would differ; claim also unexhausted in state court but denied on merits
Failure to preserve physical evidence (boulder)	Wilson: destroyed evidence was potentially exculpatory and State acted in bad faith (Youngblood)	State: destruction resulted from misclassification/negligence, not bad faith; Youngblood requires bad faith to establish constitutional violation for potentially useful evidence	Wilson failed to show bad faith; state court’s ruling was reasonable under Youngblood; habeas relief denied
Standard of review under AEDPA	Wilson: state rulings unreasonably applied clearly established federal law	State: AEDPA requires deference; state decisions were not objectively unreasonable	Court held AEDPA’s highly deferential standard not met; affirmed denial of habeas relief

Key Cases Cited

Williams v. Taylor, 529 U.S. 362 (defines AEDPA deference and "contrary to/unreasonable application" standards)
Renico v. Lett, 559 U.S. 766 (federal habeas courts cannot grant relief merely for erroneous state‑court application; must be objectively unreasonable)
Harrington v. Richter, 562 U.S. 86 (state‑court decisions entitled to deference; habeas relief barred unless no fairminded jurist could agree)
Estelle v. McGuire, 502 U.S. 62 (federal habeas limited to violations of federal law; state evidentiary rulings reviewed only for due‑process fairness)
Tome v. United States, 513 U.S. 150 (addresses prior consistent statements under Federal Rules of Evidence—not a constitutional limit on state evidentiary rules)
Brady v. Maryland, 373 U.S. 83 (prosecution must disclose exculpatory evidence)
Strickler v. Greene, 527 U.S. 263 (materiality/prejudice standard for suppressed evidence)
United States v. Bagley, 473 U.S. 667 (impeachment evidence falls within Brady disclosure obligations)
Arizona v. Youngblood, 488 U.S. 51 (due process claim for failure to preserve potentially useful evidence requires bad faith)
Montana v. Egelhoff, 518 U.S. 37 (state evidentiary rules do not generally create constitutional due‑process violations)