JOSEPH THOMAS REINER v. JEFFREY WOODS, Warden - Articles

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JOSEPH THOMAS REINER v. JEFFREY WOODS, Warden

Posted by: Tanja Trezise on Apr 7, 2020

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Matthew C. Tymann, WILMER CUTLER PICKERING HALE AND DORR LLP, Los Angeles, California, for Appellant. Jared D. Schultz, OFFICE OF THE MICHIGAN ATTORNEY GENERAL, Lansing, Michigan, for Appellee.

Attorneys 2: ON BRIEF: Matthew C. Tymann, WILMER CUTLER PICKERING HALE AND DORR LLP, Los Angeles, California, for Appellant. Jared D. Schultz, OFFICE OF THE MICHIGAN ATTORNEY GENERAL, Lansing, Michigan, for Appellee.

Judge(s): CLAY, ROGERS, and GRIFFIN, Circuit Judges

GRIFFIN, Circuit Judge. In this habeas case brought under 28 U.S.C. § 2254, both parties agree that the admission of testimonial hearsay statements during petitioner Joseph Reiner’s murder trial in Michigan state court violated his Sixth Amendment right to confront his accusers (because the declarant was never available for cross-examination). The Michigan Court of Appeals made that same determination on direct review. The issue on appeal is whether that error was harmless.

A review of the evidence presented at Reiner’s trial paints the picture of a circumstantial case lacking physical evidence or eyewitness testimony placing Reiner at the crime scene. The statements that gave rise to the Sixth Amendment violation here served as the linchpin of the government’s case, connecting Reiner to the fruits of the crime in a way no other evidence, testimonial or physical, could. Without those statements, the prosecution’s case becomes significantly weaker, such that “grave doubt” exists as to whether their admission had a “substantial and injurious effect or influence in determining the jury’s verdict.” O’Neal v. McAninch, 513 U.S. 432, 436 (1995) (citation omitted). We therefore reverse the district court’s denial of Reiner’s § 2254 petition and remand for further proceedings.

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