No. 18-8058

Joel Elias Sanchez v. Jeffrey A. Beard, Secretary, California Department of Corrections and Rehabilitation

Lower Court: Ninth Circuit
Docketed: 2019-02-21
Status: Denied
Type: IFP
Response WaivedIFP
Tags: 9th-circuit aedpa constitutional-rights crane-v-kentucky criminal-defense criminal-procedure due-process evidence-exclusion evidentiary-exclusion ninth-circuit-review right-to-present-defense self-defense
Latest Conference: 2019-03-22
Question Presented (from Petition)

The constitution guarantees criminal defendants "a meaningful opportunity to present a complete defense." Crane v. Kentucky, 476 U.S. 683, 690 (1986). At Joel Sanchez's murder trial, he sought as part of his self-defense case to present toxicological evidence that the decedent was under the influence of alcohol and methamphetamine, to corroborate his statements that the man had approached him in a threatening way that made him fear for his life. But the trial court excluded the evidence as irrelevant.

This petition presents two questions:

1. Did excluding this evidence violate Sanchez's clearly established right under Crane?

2. Did the Ninth Circuit exaggerate the degree of deference required under 18 U.S.C. § 2254(d)(1) by holding (in the alternative) that the exclusion here could not amount to an unreasonable application of the Court's existing precedents?

Question Presented (AI Summary)

Did excluding this evidence violate Sanchez's clearly established right under Crane?

Docket Entries

2019-03-25
Petition DENIED.
2019-03-11
Waiver of Jeffrey A. Beard of right to respond submitted.
2019-03-07
DISTRIBUTED for Conference of 3/22/2019.
2019-03-01
Waiver of right of respondent Jeffrey A. Beard to respond filed.
2019-02-14
Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due March 25, 2019)

Attorneys

Jeffrey A. Beard
David Delgado-RucciCalifornia Attorney General's Office, Respondent
Joel Elias Sanchez
Michael T. DrakeOffice of the Federal Public Defender for the Central District of California, Petitioner