McInnis v. Bolin
- Patrick Schiltz
- 0:22-cv-03064
- U.S. District Court · District of Minnesota
- 3
In McInnis v. Bolin, Judge Schiltz denied McInnis’s petition, dismissed the action with prejudice, and granted a certificate of appealability on one issue.
The ruling directly affected Jquan Leearthur McInnis’s federal challenge to the admission of his confession and left the denial of his petition in place. William Bolin, the warden, prevailed in the federal proceeding.
What happened
McInnis v. Bolin involved Jquan Leearthur McInnis’s petition challenging the admission of his confession in a state-court case. A magistrate judge recommended denying the petition, and McInnis objected.
The court said the confession was obtained unconstitutionally and expressed serious doubt that admitting it was harmless, especially on whether McInnis intended to kill when he fired the shot that killed J.R. But the court concluded that federal law limited its review and that the Minnesota Supreme Court’s decision was not clearly beyond reasonable disagreement.
Judge Schiltz overruled McInnis’s objection, adopted the recommendation, denied the petition, and dismissed the action with prejudice. He also granted a certificate of appealability limited to whether the Minnesota Supreme Court unreasonably applied federal law when it found the confession’s admission harmless beyond a reasonable doubt.
The detailed version
- McInnis v. Bolin · No. 0:22-cv-03064
- Patrick Schiltz
- May 27, 2025
Background
Jquan Leearthur McInnis challenged the admission of his confession in a state-court criminal case. The opinion states that the confession was obtained unconstitutionally. The Minnesota Supreme Court nevertheless concluded that admitting the confession was harmless beyond a reasonable doubt. McInnis then filed a federal petition for a writ of habeas corpus, asking for relief based on that constitutional error.
Magistrate Judge Douglas L. Micko recommended denying the petition in a February 6, 2025, Report and Recommendation. McInnis objected. Chief Judge Patrick J. Schiltz reviewed the objection and the recommendation independently, as required for an objection to a magistrate judge’s recommendation.
Court’s Analysis
The court expressed “grave doubt” that admitting the confession was harmless. In particular, it noted the trial court’s repeated discussion of what McInnis’s confession did not say when analyzing whether transferred intent had been proved. The court therefore had difficulty understanding how the Minnesota Supreme Court could find the error harmless beyond a reasonable doubt.
The court nevertheless held that the Antiterrorism and Effective Death Penalty Act, together with controlling Supreme Court precedent, restricted federal review of the state court’s decision. Under that standard, the state court’s decision could be overturned only if it was so obviously wrong that no fair-minded disagreement was possible. The court reluctantly concluded that the Minnesota Supreme Court’s unanimous decision, although likely wrong, did not meet that standard.
Ruling
Judge Patrick J. Schiltz overruled McInnis’s objection and adopted the Report and Recommendation. The court denied McInnis’s petition and dismissed the action with prejudice. It granted a certificate of appealability only on this question: whether the Minnesota Supreme Court unreasonably applied federal law when it concluded that any error in admitting McInnis’s unconstitutionally obtained confession was harmless beyond a reasonable doubt.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.