Taylor v. McKee, 649 F.3d 446

Sean Taylor was convicted in Michigan of felony murder and related offenses; he was sentenced to life plus substantial terms.
Taylor claimed his trial was unfair because he was walked in front of the venire panel in shackles, allegedly prejudiceing jurors.
The Michigan Court of Appeals reviewed the shackling claim for plain error due to lack of contemporaneous objection and upheld that standard.
The Michigan Supreme Court denied leave to appeal; one justice dissented on a non-relevant issue.
Taylor filed a pro se habeas petition in federal court; the district court denied relief and did not address some procedural-default defenses.
The Sixth Circuit affirmed, holding the shackling claim procedurally defaulted and not excused by cause and prejudice, including ineffective-assistance arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether shackling in front of the venire violated due process	Taylor argues shackling created constitutional error warranting relief.	Warden contends no automatic violation; only plain error if prejudicial evidence appeared.	Shackling claim procedurally defaulted; no relief on merits.
Whether the shackling claim was procedurally defaulted under adequate state grounds	District court should reach merits despite default.	Michigan's contemporaneous-objection rule and plain-error review constitute adequate independent grounds.	Claim defaulted; independent state ground forecloses federal review.
Whether cause and prejudice excused the procedural default, including ineffective assistance	Ineffective assistance of trial and appellate counsel constitutes cause.	Ineffective-assistance claims were not exhausted and cannot serve as cause; also post-conviction counsel issues do not create constitutional rights under these facts.	No cause and prejudice; ineffective-assistance claims not exhausted; default stands.
Whether prison-law-library access or appellate-counsel issues could excuse default	Law-library deficiencies and appellate-counsel failure justify relief.	No entitlement to counsel in post-conviction proceedings; library access insufficient for meaningful access to courts.	No excusal; no merit to excusing default.

Lundgren v. Mitchell, 440 F.3d 754 (6th Cir. 2006) (procedural default framework for fed habeas claims)
Edwards v. Carpenter, 529 U.S. 446 (U.S. 2000) (cause and prejudice required for defaulted ineffectiveness claims)
Murray v. Carrier, 477 U.S. 478 (U.S. 1986) (exhaustion rule and cause for ineffective assistance)
Coleman v. Thompson, 501 U.S. 722 (U.S. 1991) (no constitutional right to counsel in state post-conviction proceedings)
Bounds v. Smith, 430 U.S. 817 (U.S. 1977) (meaningful access to the courts; library and legal assistance considerations)
Dixon v. Clem, 492 F.3d 665 (6th Cir. 2007) (circuit affirmation on alternative correct reasoning)
Willis v. Smith, 351 F.3d 741 (6th Cir. 2003) (adequacy of state procedural rules for default analysis)
Abdus-Samad v. Bell, 420 F.3d 614 (6th Cir. 2005) (agency attributions of post-conviction attorney errors)