Lema v. The People

Background

Christopher Lema filed a federal petition for a writ of habeas corpus, asking the court to review a claim arising from his state criminal case. The opinion refers to an allegedly erroneous response by the trial court to a jury question and to Lema’s argument that the evidence supported manslaughter rather than murder.

Court’s analysis

The court stated that Lema’s claim was procedurally defaulted, meaning that a state procedural rule may have prevented federal review. The court nevertheless addressed the claim in the alternative. It assumed that the claim was not procedurally defaulted and that the trial court’s response to the jury’s question could support a federal due-process claim.

Applying the harmless-error standard from Brecht v. Abrahamson, the court concluded that the alleged error almost certainly did not have a substantial and injurious effect on the verdict. The court relied on the reasons given by the California Court of Appeal in its harmless-error analysis, including what the federal court described as virtually no evidence supporting Lema’s assertion that he committed manslaughter instead of murder.

Disposition

The court denied the petition for a writ of habeas corpus. It also denied a certificate of appealability, finding that reasonable judges would not debate or find wrong the court’s assessment of the constitutional claims. The clerk was directed to enter judgment in favor of the respondent and close the file.

The footnote directs the clerk to substitute Acting Warden Matthew Atchley as respondent because the opinion identifies him as Lema’s current custodian.