| 25-6725 |
Shawn D. Powell v. Fidencio Guzman, Warden |
Ninth Circuit |
2026-02-05 |
Pending |
IFP |
closing-argument habeas-corpus ineffective-assistance strickland-standard trial-counsel witness-credibility |
During closing argument at Petitioner Shawn Powell's trial, his trial counsel unreasonably conceded Powell's guilt of vandalism and violation of a pro… |
| 25A650 |
Alabama v. Brandon Dewayne Sykes |
Alabama |
2025-12-03 |
Application |
|
closing-argument fifth-amendment griffin-violation harmless-error prosecutorial-comment self-incrimination |
Whether a prosecutor's comments during closing argument that implicitly reference a defendant's choice not to testify violate the Fifth Amendment's pr… |
| 25-5545 |
Miguel Angel Homedes v. United States |
Sixth Circuit |
2025-09-04 |
Denied |
Response WaivedIFP |
appellate-review closing-argument due-process evidentiary-rules prosecutorial-misconduct trial-procedure |
Whether improper prosecutorial statements in closing argument are sufficiently flagrant to warrant reversal, where they inserted facts not directly in… |
| 23-7697 |
Zachary Kelsey v. Tim Garrett, Warden, et al. |
Ninth Circuit |
2024-06-12 |
Denied |
Response WaivedIFP |
cause-of-death closing-argument criminal-procedure criminal-trial forensic-pathologist forensic-pathology habeas-corpus ineffective-assistance-of-counsel second-degree-murder sixth-amendment |
Whether Zachary Kelsey was deprived of the effective assistance of counsel |
| 23-7619 |
Brandon Gibbs v. Texas |
Texas |
2024-06-03 |
Denied |
IFP |
closing-argument constitutional-rights criminal-procedure due-process fifth-amendment prosecutorial-misconduct self-incrimination |
Did prosecutor improperly comment on Petitioner's failure to testify during closing argument, in violation of the Fifth Amendment? |
| 23-7544 |
Rodolfo Morales-Cortez v. United States |
Ninth Circuit |
2024-05-22 |
Denied |
Response WaivedIFP |
burden-of-proof closing-argument criminal-procedure defendant-rights due-process objection-standard prejudice prosecutorial-misconduct |
Does a defendant who timely objects to a prosecutor's misconduct during closing argument nevertheless bear the burden to show that it caused him preju… |
| 23-7319 |
Yudith Reynoso-Hiciano v. United States |
Second Circuit |
2024-04-26 |
Denied |
Response WaivedIFP |
aiding-and-abetting burden-of-proof closing-argument criminal-procedure jury-instructions presumption-of-innocence reasonable-doubt |
Whether repeatedly arguing in closing that the defendant 'needed the jury to believe' certain things impermissibly shifted the burden of proof and evi… |
| 23-5257 |
Angel Rios-Edeza v. United States |
Ninth Circuit |
2023-08-01 |
Denied |
Response WaivedIFP |
burden-of-proof closing-argument criminal-procedure due-process evidence-vouching jury-instructions ninth-circuit prosecutorial-misconduct rebuttal-argument |
Did the Ninth Circuit error in finding that there was no prosecutorial misconduct? |
| 22-7536 |
Mark D. Sievers v. Florida |
Florida |
2023-05-12 |
Denied |
IFP |
closing-argument due-process fair-trial jury-instruction plea-agreement polygraph prosecutorial-misconduct witness-credibility |
Whether a state judge violates a defendant's due process right to a fair trial by giving an impromptu jury instruction regarding the credibility of th… |
| 22-905 |
Troy A. Gregory v. United States |
Tenth Circuit |
2023-03-17 |
Denied |
Response Waived |
closing-argument confession due-process hypothetical identification prosecutorial-misconduct |
Can a prosecutor act out a hypothetical confession by the defendant in closing argument when it is uncontested that the defendant did not confess? |
| 21-7449 |
Leonard S. Taylor v. Paul Blair, Warden |
Eighth Circuit |
2022-03-23 |
Denied |
IFP |
capital-punishment capital-trial closing-argument ineffective-assistance ineffective-assistance-of-counsel martinez-standard martinez-v-ryan mccoy-v-louisiana nixon-v-florida sixth-amendment strickland-test strickland-v-washington |
Whether the decision to forego a closing argument in the penalty phase of a capital murder trial is a tactical decision for trial counsel to make or a… |
| 21-7289 |
Katrina Brown v. United States |
Eleventh Circuit |
2022-03-07 |
Denied |
Response WaivedIFP |
closing-argument criminal-procedure fair-trial judicial-error motion-for-severance prejudice right-to-counsel severance standby-counsel |
whether-the-district-court-committed-error-by-ordering-the-defendant-to-go-forward-with-closing-argument-without-standby-counsel |
| 21-7260 |
George K. Mackie v. Massachusetts |
Massachusetts |
2022-03-02 |
Denied |
Response WaivedIFP |
closing-argument criminal-procedure impeachment ineffective-assistance ineffective-assistance-of-counsel jury-instructions miscarriage-of-justice prosecutorial-misconduct reasonable-doubt |
Did the appeals court err in holding that the error-laden closing argument by the prosecutor, taken in its totality, create a substantial risk of a mi… |
| 21-7040 |
Harshadkumar Nanjibhai Jadav v. J. Woodson, Warden |
Virginia |
2022-02-01 |
Denied |
IFP |
closing-argument constitutional-rights due-process fair-trial false-evidence prosecutorial-misconduct trial-procedure |
Does the prosecutor's deliberate use of known false evidence during closing argument violate the accused's Constitutional rights? |
| 21-6475 |
Mark Hollingsworth v. Maryland |
Maryland |
2021-12-03 |
Denied |
IFP |
brady-violation closing-argument criminal-procedure due-process false-testimony jury-argument napue-v-illinois napue-violation prosecutorial-misconduct right-to-fair-trial |
Did the Maryland State Courts err in finding that the Prosecutor did not violate Napue v. Illinois, 360 U.S. 264 (1959) when the Prosecutor argued to … |
| 21-5889 |
Anibal Alejandro Hernandez v. Bobby Lumpkin, Director, Texas Department of Criminal Justice, Correctional Institutions Division |
Fifth Circuit |
2021-10-12 |
Denied |
IFP |
closing-argument courtroom-security criminal-procedure due-process fair-trial ineffective-assistance-of-counsel prejudicial-statements shackling trial-shackling |
Was Petitioner denied the effective assistance of counsel when his trial counsel failed to object to Petitioner being ordered to be shackeled during t… |
| 21-5135 |
Michael Ray Orr v. Texas |
Texas |
2021-07-19 |
Denied |
Response WaivedIFP |
closing-argument criminal-procedure defendant-rights demeanor fifth-amendment prosecutorial-misconduct self-incrimination trial-procedure |
Did the trial court err by denying Mr. Orr's objection to improper closing argument by the prosecutor? |
| 21-41 |
James Allen Jackson v. Texas |
Texas |
2021-07-13 |
Denied |
Response Waived |
closing-argument constitutional-rights criminal-procedure habeas-corpus ineffective-assistance ineffective-assistance-of-counsel prejudice procedural-due-process racist-testimony right-to-silence trial-counsel wiccan-testimony |
Was petitioner denied effective-assistance-of-counsel,racist-testimony,wiccan-testimony,right-to-silence,closing-argument,prejudice |
| 20-1712 |
Charles Paul-Thomas Phoenix v. The Florida Bar |
Florida |
2021-06-10 |
Denied |
Response Waived |
attorney-disciplinary-proceeding attorney-discipline charge-not-in-original closing-argument due-process grievance-committee in-re-ruffalo probable-cause quasicriminal-nature |
Whether a charge, in a state bar attorney disciplinary proceeding for which the attorney grievance committee had determined there was no probable caus… |
| 20-8203 |
Dasheme Kareme Hosley v. Rick Hill, Warden |
Ninth Circuit |
2021-06-02 |
Denied |
Response WaivedIFP |
closing-argument due-process harmless-error judicial-ratification jury-instruction jury-instructions legal-misstatement prosecutorial-misconduct trial-court trial-procedure |
Should courts presume that the jury followed the trial court's correct instruction at the end of trial even if the trial judge expressly ratified a mi… |
| 20-6871 |
Angnem Green v. New York |
New York |
2021-01-13 |
Denied |
IFP |
closing-argument constitutional-rights criminal-procedure due-process equal-protection fair-trial prosecutorial-misconduct racial-bias racial-discrimination |
Whether the New York Appellate Division, Fourth Judicial Department erred in finding Petitioner's Constitutional right to a fair trial was not violate… |
| 20-5389 |
Milkiyas Bayisa v. United States |
District of Columbia |
2020-08-18 |
Denied |
Response WaivedIFP |
appellate-procedure closing-argument constitutional-rights due-process judicial-review prosecutorial-misconduct rebuttal religious-references |
Whether the prosecutor's repeated references to God during rebuttal closing argument constituted highly prejudicial prosecutorial misconduct resulting… |
| 20-5154 |
Jorge Armando Herrera Salguero v. California |
Ninth Circuit |
2020-07-23 |
Denied |
Response WaivedIFP |
certificate-of-appealability closing-argument credibility due-process habeas habeas-corpus prosecutorial-misconduct witness-credibility |
Whether the Ninth Circuit's denial of a COA on Salguero's prosecutorial-misconduct claim is contrary to this Court's jurisprudence |
| 19-8335 |
Mitchell Willoughby v. Deedra Hart, Warden |
Sixth Circuit |
2020-04-22 |
Denied |
IFP |
caldwell-precedent capital-sentencing closing-argument death-penalty jury jury-instructions prosecutor prosecutorial-misconduct sixth-circuit state-law voir-dire |
Did the Sixth Circuit panel misunderstand or frustrate the purpose behind this court's holding in Caldwell v. Mississippi |
| 19-7590 |
David K. Howell v. Shawn Hatton, Warden |
Ninth Circuit |
2020-02-07 |
Denied |
Response WaivedIFP |
certificate-of-appealability closing-argument criminal-procedure due-process expert-testimony habeas habeas-corpus ineffective-assistance-of-counsel intoxication methamphetamine methamphetamine-intoxication sixth-amendment |
Is the Ninth Circuit's denial of a COA on Howell's ineffective-assistance-of-counsel claim contrary to this Court's jurisprudence? |
| 18-7858 |
Arif Majid v. Jeff Noble, Warden |
Sixth Circuit |
2019-02-08 |
Denied |
Response WaivedIFP |
burden-of-proof closing-argument constitutional-rights due-process fair-trial jury-bias jury-instructions prosecutorial-misconduct religious-prejudice trial-fairness |
Whether a prosecutor's appeals to religious prejudice in closing argument and throughout trial to inflame the passions of the jury embody animus or of… |
| 18-7834 |
Brent William Bogseth v. Michigan |
Michigan |
2019-02-07 |
Denied |
IFP |
14th-amendment 5th-amendment closing-argument constitutional-rights criminal-procedure deliberation due-process evidence fair-trial fifth-amendment murder premeditation prosecutorial-misconduct self-incrimination |
Whether the lack of evidence to show the defendant actually committed the offense of murder means premeditation and deliberation cannot exist, or if t… |
| 18-7434 |
Christopher Adin Graham v. United States |
Ninth Circuit |
2019-01-15 |
Denied |
Response WaivedIFP |
28-usc-2253 appellate-procedure certificate-of-appealability closing-argument counsel-claims due-process habeas-corpus ineffective-assistance ineffective-assistance-of-counsel judicial-review legal-standard prejudice testimony |
Whether the court of appeals correctly denied petitioner a certificate of appealability under 28 U.S.C. 2253(c) on his ineffective-assistance-of-couns… |
| 18-7265 |
Rodney Scot Armstrong, Jr. v. Michigan |
Michigan |
2019-01-07 |
Denied |
IFP |
civil-procedure closing-argument de-novo-review directed-verdict legal-preservation motion objection preservation-of-error preservation-of-issues prosecutorial-misconduct standard-of-review trial-procedure |
Is a motion for a directed verdict an objection that preserves an issue for and mandates de novo review? |
| 18-7089 |
Esau Milliner v. Kathy Litteral, Warden |
Sixth Circuit |
2018-12-19 |
Denied |
Response WaivedIFP |
appeal-waiver closing-argument confession constitutional-rights criminal-procedure due-process first-degree-burglary ineffective-assistance-of-counsel initial-aggressor procedural-bar right-to-appeal right-to-testify self-defense trial-counsel |
Effective-assistance-of-counsel |
| 18-6701 |
Roger Dale Epperson v. Kentucky |
Kentucky |
2018-11-14 |
Denied |
IFP |
client-autonomy closing-argument concession-of-guilt criminal-procedure defense-strategy ineffective-assistance ineffective-assistance-of-counsel mccoy-v-louisiana right-to-control-defense right-to-counsel sixth-amendment |
Is a defendant's Sixth Amendment right to counsel, and the right to control the objective of the defense, violated, under the Court's recent decision … |
| 18-5563 |
Peter Cain Bruton v. Lorie Davis, Director, Texas Department of Criminal Justice, Correctional Institutions Division |
Fifth Circuit |
2018-08-13 |
Denied |
IFP |
closing-argument extraneous-offenses ineffective-assistance ineffective-assistance-of-counsel mistrial motion-in-limine prosecutorial-misconduct trial-counsel violation violation-of-court-order |
Is an attorney ineffective when he fails to support a motion for mistrial with a violation of Defense's Motion in Limine? |
| 18-5464 |
Jose Benitez, Jr. v. United States |
Eleventh Circuit |
2018-08-03 |
Denied |
Response RequestedResponse WaivedRelisted (2)IFP |
armed-bank-robbery closing-argument constructive-amendment criminal-procedure due-process firearm firearm-specification indictment indictment-variance jury-instructions prosecutorial-discretion variance |
Whether a constructive amendment occurred when the jury instructions and government's closing argument allowed conviction for armed bank robbery witho… |
| 18-5433 |
Helen Atkins v. Julie L. Jones, Secretary, Florida Department of Corrections |
Eleventh Circuit |
2018-08-01 |
Denied |
Response WaivedIFP |
closing-argument constitutional-rights due-process effective-assistance-of-counsel fair-trial hearsay-evidence ineffective-assistance-of-counsel jury-instructions prosecutorial-misconduct right-to-testify sixth-amendment speedy-trial |
Was the petitioner denied her right to a fair trial and effective assistance of counsel? |