Wayne Clyde Mezzles v. John N. Katavich, Warden
DueProcess HabeasCorpus Punishment
Does the state's application of a forfeiture bar for failure to request additional admonitions discriminate against federal claims?
QUESTIONS PRESENTED Before trial, the court ruled that defense expert Robert Owen could testify about Mezzles’s PTSD but not about his capacity to form the specific intent required to convict on the criminal threats charges or whether he had in fact formed that intent. Nevertheless, the prosecutor repeatedly asked the expert questions on these forbidden topics, and the numerous defense objections he provoked made it falsely appear that the defense was hiding important information from the jury and that, had the information been disclosed, it would have hurt the defense. The state court concluded deliberate prosecutorial misconduct had occurred, but that the claim had either been forfeited by defense counsel’s failure to request “additional admonitions,” or the intentional misconduct was harmless. Mezzles was sentenced to 80-years-to-life from a single incident of domestic violence. (1) Does the state’s application of a forfeiture bar for failure to request additional admonitions discriminate against federal claims when the trial court concluded the jury had been adequately admonished in the wake of defense counsel’s sixteen objections and motion for a mistrial? (2) Was the state court reasonable in finding harmlessness when the deliberate prosecutorial misconduct went to the heart of the defense case, a jury note and the length of deliberations suggest the jury viewed Mezzles’s guilt as a close question, and the court’s conclusion was based solely on the presumption that jurors follow their instructions? (3) Is the 80-years-to-life sentence grossly disproportionate to the crimes? i