Armfield v. Nicklaus

Federal 7th Circuit Court
Criminal Court
Confrontation Clause
Citation
Case Number: 
No. 18-3702
Decision Date: 
January 11, 2021
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Dist. Ct. did not err in denying defendant’s habeas petition, alleging that inadvertent disclosure to jury of transcript containing prosecutor’s opening statement in co-defendant’s separate trial, indicating that co-defendant had given statement implicating defendant in charged murder violated his 6th Amendment rights under Confrontation Clause. Any error caused by defendant’s inability to confront co-defendant’s statement was harmless, where govt. presented solid case against defendant that included two witnesses placing defendant and others at scene of shooting, as well as other unconnected witnesses, who confirmed defendant’s role as one of two shooters of victim. Moreover, instant prosecutor did not discuss co-defendant’s statement implicating defendant in shooting. Also, Dist. Ct. did not err in rejecting defendant’s claim that his counsel was ineffective for failing to object to evidence of subsequent shooting that resulted in capture of gun that was involved in instant charged offense, where, although defendant was not involved in said shooting, any failure to object to said testimony was harmless given strength of govt. case against defendant in charged offense.