Woods v. Donald

PETITIONER: Jeffrey Woods, Warden
RESPONDENT: Cory Donald
LOCATION: Frank Murphy Hall of Justice

DOCKET NO.: 14-618
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 575 US (2015)
GRANTED: Mar 30, 2015
DECIDED: Mar 30, 2015

Facts of the case

Cory Donald, Seante Liggins, Rashad Moore, Dewayne Saine, and Fawzi Zaya decided to rob Mohammed Makki, a local drug dealer. During the course of the robbery, several shots were fired and Makki was later discovered dead. Liggins and Zaya pled guilty, and Donald was tried with Moore and Saine for one count of first-degree felony murder and two counts of armed robbery. When the government sought to admit evidence of phone communication among the defendants on the day in question, Donald’s lawyer indicated that evidence did not affect his client, so the judge allowed testimony to proceed when Donald’s lawyer was not in the courtroom. The jury convicted Donald on all three counts. He appealed and argued that his lawyer’s absence from the courtroom during the phone call testimony denied him his Sixth Amendment right to effective assistance of counsel. The Michigan Court of Appeals rejected the claim and the Michigan Supreme Court denied review.

Donald moved for federal habeas relief, which the district court granted, and the U.S. Court of Appeals for the Sixth Circuit affirmed by holding that the Michigan Court of Appeals did not properly apply the precedent established by the Supreme Court’s decision in United States v. Cronic. In that case, the Court held that courts may presume a defendant’s Sixth Amendment rights have been violated when he is denied the assistance of counsel at a critical stage in his trial, which the appellate court found happened in this case.

Question

Did the U.S. Court of Appeals for the Sixth Circuit properly affirm the granting of federal habeas relief by holding that the Michigan Court of Appeals improperly applied Supreme Court precedent?

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