Winfield v. O'Brien, 2014 U.S. App. LEXIS 23883

Two-year-old victim suffered vaginal and anal burns, tears, skull fracture, and other injuries after being in care at defendant Keith Winfield's home on Oct. 11–13, 2005; medical experts opined burns consistent with a hot cylindrical instrument (e.g., curling iron) inflicted within 24–36 hours before midnight Oct. 14.
The victim was regularly left with Winfield’s wife Patricia; on Oct. 13 Winfield said he was at home and alone with the victim and his infant daughter for roughly 45–60 minutes midday.
The victim’s grandmother picked the child up in the afternoon and observed genital swelling; the mother later found blistering and bleeding and sought emergency care.
Police interviewed Winfield; he gave a recorded statement denying assault, admitting displeasure about having the child in the home, and acknowledging being home that day; a small curling iron was present in the bathroom.
A jury convicted Winfield of two counts of Rape of a Child and related charges; Massachusetts appellate courts affirmed. Winfield filed a federal habeas petition under 28 U.S.C. § 2254 challenging (1) sufficiency of the evidence and (2) exclusion of cross-examination about the victim-mother’s later criminal charges. The district court denied relief; the First Circuit affirmed.

Issue	Plaintiff's Argument (Winfield)	Defendant's Argument (Commonwealth)	Held
Sufficiency of the evidence to prove Winfield (not Patricia) committed the rape	Evidence only narrowed suspects; guilt of Winfield vs. wife was equivocal and insufficient to sustain conviction beyond a reasonable doubt	Circumstantial evidence (Winfield alone with child during injury window, medical timing, curling-iron consistency, phone evidence, statements) permitted a rational jury to find Winfield guilty	Affirmed: state courts reasonably concluded evidence sufficient under Jackson/AEDPA; opportunity and timing supported conviction
Exclusion of cross-examining victim’s mother about her later pending criminal charges (bias impeachment)	Mother’s pending prescription-fraud charges showed state leverage and possible motive to fabricate; exclusion violated Confrontation Clause	Charges were filed over a year after her prior statements/testimony; remote in time and at best marginally probative of bias; trial allowed other bias impeachment	Affirmed: exclusion was not an unreasonable application of Confrontation Clause precedent (e.g., Davis) under AEDPA

Jackson v. Virginia, 443 U.S. 307 (established standard for sufficiency of the evidence in criminal cases)
Davis v. Alaska, 415 U.S. 308 (cross-examination for bias when interest or motive is operative at time of testimony)
Harrington v. Richter, 562 U.S. 86 (state-court decision need not include detailed reasoning for AEDPA review)
Leftwich v. Maloney, 532 F.3d 20 (AEDPA requires more than error; decision must be objectively unreasonable)
O'Laughlin v. O'Brien, 568 F.3d 287 (circuit discussion of evidentiary equipoise and reversal standard)
United States v. Brown, 603 F.2d 1022 (circumstantial evidence may sustain conviction if it permits a conclusion beyond a reasonable doubt)