Samuel Moreland v. Margaret Bradshaw
2012 U.S. App. LEXIS 23420
6th Cir.2012Background
- Moreland, an Ohio death-row inmate, was convicted in 1986 by a three-judge panel of five aggravated murders with death specifications and related counts; he challenged sufficiency of evidence, competency of a child eyewitness, exclusion of expert testimony, and ineffective assistance of counsel via a federal habeas petition under AEDPA.
- The prosecution relied on eyewitness Dayron Talbott, physical evidence (blood types on Moreland’s clothing, rifle linkage), and Moreland’s statements to place him as killer with prior calculation and design.
- The state Supreme Court affirmed guilt and noted Moreland’s intoxication evidence did not negate prior calculation and design; issues about Dayron’s competence and expert testimony were treated as state-law due-process questions.
- The district court applied AEDPA deferential review to the Ohio Supreme Court’s sufficiency ruling and rejected the other federal claims after analysis under Strickland and due-process standards.
- Moreland contends Hagans or others could have been the killer; the state courts weighed conflicting inferences in favor of the prosecution, and the federal court reviews for reasonableness under AEDPA.
- Ultimately the district court denied habeas relief and the court of appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for prior calculation and design | Moreland lacked sufficient evidence | State proved calculation and design beyond doubt | Sufficient evidence supported conviction |
| Competency hearing and expert testimony on Dayron | Trial court erred by not holding full competency hearing and excluding testimony | State-law grounds supported ruling; no federal due-process violation | No due-process violation; state-law determinations affirmed |
| Ineffective assistance: gruesome photos, Doyle violations, post-arrest statements | Counsel failed to object to prejudicial photos and post-arrest statements | No prejudice under Strickland; state court reasonable | No ineffective-assistance relief warranted; not contrary to clearly established law |
| Ineffective assistance at sentencing phase | Counsel failed to investigate mitigating evidence and witnesses | Investigation strategy reasonable; no prejudice | No sentencing-phase relief; state court reasonable under Strickland |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. (1979)) (sufficiency standard for evidence: rational finder could convict)
- Strickland v. Washington, 466 U.S. 668 (U.S. (1984)) (ineffective assistance standard; prejudice component)
- Doyle v. Ohio, 426 U.S. 610 (U.S. (1976)) (prosecution cannot use post-arrest silence to impeach)
- Buell v. Mitchell, 274 F.3d 337 (6th Cir. 2001) (no constitutional right to eyewitness-identification expert testimony)
- Hill v. Mitchell, 400 F.3d 308 (6th Cir. 2005) (certificate of appealability scope)
- McGuire v. Ohio, 619 F.3d 623 (6th Cir. 2010) (AEDPA deferential review for sufficiency; two-layer approach)