Eley v. Erickson

The Facts

The petitioner was a member of conspiracy and committed four murders that were allegedly part of the crime scheme consisting of insurance fraud, illegal acquisition of deadly weapon and robbery carried out by inflicting bodily injuries and death.

Procedural History

The US Court of Appeals reversed the district court’s denial of the prisoner’s habeas petition. It also remanded the case with instructions that the district court order that the Commonwealth retry the prisoner within 120 days or else dismiss the charges against him and release him from custody


The Antiterrorism and Effective Death Penalty Act of 1996 reflects the view that habeas corpus is a guard against extreme malfunctions in the state criminal justice systems, not a substitute for ordinary error correction through appeal.

Due Process Clause requires to prove the offense is purely a matter of federal law.

The Sixth Amendment provides, inter alia, that in all criminal prosecutions, the accused shall enjoy the right to be confronted with the witnesses against him.

The Issue

(a) whether the evidence was insufficient to support defendant’s convictions in violation of the Due Process Clause of the Fourteenth Amendment under Jackson v. Virginia; (b) whether defendant’s non-testifying co-defendants’ confessions were admitted against him in violation of the Confrontation Clause of the Sixth Amendment under Bruton v. United States and its progeny; and (c) whether the trial judge’s reasonable doubt jury instruction improperly reduced the Commonwealth’s burden of proof.

The Holding/Reasoning

a) On first issue: The US Supreme Court explained that “upon a sufficiency of the evidence challenge, the federal habeas court reviews the evidence with reference to the substantive elements of the criminal offense as defined by state law. But the court also recognizes that the minimum amount of evidence that the Due Process Clause requires to prove the offense is purely a matter of federal law”. The US Supreme Court confirmed judgment of the District Court that Eley was not entitled to habeas relief because there was no persuasive evidence that the court violated Due Process Clause when he was convicted of second-degree murder, robbery, and conspiracy to commit robbery based on insufficient evidence.

b) It was asserted that admission of a non-testifying codefendant’s confession with a proper limiting instruction did not violate Confrontation Clause whereas “the confession is redacted to eliminate not only the defendant’s name, but any reference to . . . her existence.”. The Court explained that the confession at issue “was not incriminating on its face, and became so only when linked with evidence introduced later at trial”.

c) The Court admitted that the decision of the state court could be based on an unreasonable determination of the facts only if court’s findings are objectively unreasonable in light of the factual evidence. The petitioner has had to bear the burden of rebutting the presumption by clear and convincing evidence.

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