Watson v. Greene
640 F.3d 501
2d Cir.2011Background
- Watson was convicted of first-degree murder for Morris's homicide in Brooklyn; Harvey was co-defendant who claimed Watson shot Morris.
- Harvey later testified for the prosecution, claiming Watson was the shooter, in exchange for a lighter sentence.
- The Harvey Note, a memorandum allegedly stemming from Officer Pierce, suggested Harvey had a gun that went off accidentally; its existence and origin were disputed.
- Bond, the lead detective, questioned Harvey but did not confront him with Harvey Note information and did not pursue Harvey as shooter.
- Defense sought to cross-examine Bond about the Harvey Note to challenge the thoroughness of the police investigation; trial court limited this cross-examination.
- The district court granted habeas relief on Confrontation Clause grounds, focusing on the preclusion of cross-examination; the Second Circuit reversed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Confrontation Clause violation from cross-exam restriction | Watson argues the restriction violated the Sixth Amendment. | Greene argues the court properly limited cross-examination as within discretion and probative limits. | Not an unreasonable application of federal law; no violation under AEDPA |
| Whether the state court's denial was an unreasonable application of clearly established federal law | Watson contends the Appellate Division unreasonably applied law by affirming exclusion. | Greene contends the decision was reasonable given balancing of probative value and potential confusion. | Appellate Division's decision was reasonable; habeas relief denied |
Key Cases Cited
- Delaware v. Van Arsdall, 475 U.S. 673 (1986) (limits on cross-examination depend on balancing probative value and prejudice)
- Crane v. Kentucky, 476 U.S. 683 (1986) (meaningful opportunity to present a defense)
- Brinson v. Walker, 547 F.3d 387 (2d Cir. 2008) (right to cross-examine for meaningful opportunity)
- Davis v. Alaska, 415 U.S. 308 (1974) (cross-examination to test witness credibility)
- Kyles v. Whitley, 514 U.S. 419 (1995) (prosecution's disclosure obligations and thoroughness of investigation)
- Taylor v. Illinois, 484 U.S. 400 (1988) (standard for admissibility and evidentiary balancing)
- Wade v. Mantello, 333 F.3d 51 (2d Cir. 2003) (broad discretion in evidentiary rulings; abuse of discretion review)
- Renico v. Lett, 130 S. Ct. 1855 (2010) (AEDPA deference and unreasonable application standard)
- Harrington v. Richter, 131 S. Ct. 770 (2011) (need for a reasonable basis for state-court decision under AEDPA)
- Yarborough v. Alvarado, 541 U.S. 652 (2004) (general vs. specific rules under AEDPA)