Durant v. Matteson

Background

Anthony L. Durant filed a petition under 28 U.S.C. § 2254 challenging his state-court criminal proceedings. He represented himself in the federal case. His petition raised claims concerning jury instructions, the admission of evidence, and prosecutorial misconduct.

Under the Antiterrorism and Effective Death Penalty Act, or AEDPA, a federal court generally may grant relief only if the state court’s decision was contrary to clearly established United States Supreme Court law, unreasonably applied that law, or rested on an unreasonable determination of the facts. The court described this as a highly deferential standard.

Court’s Analysis

The court held that it was not objectively unreasonable for the state courts to conclude that the trial court’s failure to instruct the jury on heat of passion, self-defense, defense of others, imperfect self-defense, imperfect defense of others, and accomplice liability did not violate Durant’s constitutional rights.

The court also held that it was not objectively unreasonable for the state courts to conclude that admitting evidence about “rumors on the street” concerning a “beef” between Durant and Sheppard did not violate his constitutional rights.

Regarding prosecutorial misconduct, the court held that it was not objectively unreasonable for the state courts to conclude that the prosecutor’s conduct did not make the trial fundamentally unfair. Durant separately argued that his trial lawyer’s failure to object to the alleged misconduct caused him to lose appellate review. The court called that claim moot because the California Court of Appeal had addressed the merits of each misconduct claim.

Disposition

The court denied the petition for a writ of habeas corpus. It also denied a certificate of appealability, finding that reasonable jurists would not disagree about the assessment of Durant’s constitutional claims. Judge Vince Chhabria ordered the Clerk to enter judgment for the respondent, Gigi Matteson, and close the file.