Stricklin v. Capra
1:20-cv-01918
E.D.N.YJul 15, 2024Background
- Stacy Stricklin was convicted of second-degree murder in New York after killing Michelle Fernandez in her apartment following a party where he used alcohol and cocaine.
- At trial, Stricklin pursued an intoxication defense, supported by witness testimony and an expert.
- Key evidence included a surveillance video from the victim's apartment building and forensic evidence (bite marks matching Stricklin).
- Stricklin was convicted after a bench trial and received a sentence of 25 years to life; his convictions were affirmed and his § 440.10 motion denied by state courts.
- Stricklin filed a federal habeas petition under 28 U.S.C. § 2254, raising six claims: ineffective assistance of counsel, Confrontation Clause violation, prosecutorial misconduct, Rosario violation, improper modification of a Sandoval ruling, and deprivation of a preliminary hearing.
- The district court reviewed whether any of these claims warranted federal habeas relief under AEDPA standards and found none did.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance of counsel | Counsel failed to properly review surveillance video and advise on decisions. | Counsel's review was timely and not prejudicial. | Denied – no Strickland violation. |
| Sandoval ruling (admission of priors) | Trial court reversed itself allowing prior conviction, which was unfair. | Admitted for limited, permissible purpose (affecting expert's view). | Denied – not fundamentally unfair. |
| Confrontation Clause violation | Out-of-court statements from non-testifying witness violated rights. | Issue unpreserved; statements not for truth of matter asserted. | Procedurally barred and meritless. |
| Deprivation of preliminary hearing | Denial of statutory right amounts to constitutional defect. | Claim is procedurally barred under state law. | Procedurally barred on independent ground. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (defining ineffective assistance of counsel standard)
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence)
- Coleman v. Thompson, 501 U.S. 722 (federal habeas procedural default doctrine)
- Harrington v. Richter, 562 U.S. 86 (AEDPA deference standard for unreasonable application)
- Williams v. Taylor, 529 U.S. 362 (contrary to/unreasonable application under AEDPA defined)
- People v. Rosario, 9 N.Y.2d 286 (New York rule on disclosure of witness statements)
- People v. Sandoval, 34 N.Y.2d 371 (New York rule on impeachment with prior convictions)