AEDPA bars habeas relief on speedy trial claim

The 4th U.S. Circuit Court of Appeals reversed a federal habeas order granting relief to a South Carolina inmate, holding that the U.S. District Court failed to apply the highly deferential review required by the Antiterrorism and Effective Death Penalty Act.

The defendant was convicted in South Carolina of armed robbery, kidnapping, first-degree burglary and criminal conspiracy arising from a home invasion robbery. After unsuccessfully challenging his convictions on direct appeal and in state postconviction proceedings, he sought federal habeas relief. He argued that the nearly 23-month delay between arrest and trial violated his Sixth Amendment right to a speedy trial and that trial counsel was ineffective for failing to object to testimony describing an informant’s tip.

The 4th Circuit concluded that the U.S. District Court improperly substituted its own judgment for that of the South Carolina Supreme Court. Applying Barker v. Wingo, the state court had determined that much of the delay resulted from legitimate difficulties locating a qualified Mandarin interpreter for the victims and from complications involving a cooperating codefendant. The 4th Circuit emphasized that AEDPA permits federal relief only when a state court’s decision is objectively unreasonable, not merely incorrect. Because fair-minded jurists could agree with the state court’s weighing of the speedy trial factors, including the lack of demonstrated prejudice to the defense, habeas relief was unavailable.

The court also rejected the ineffective assistance claim. The state postconviction court reasonably concluded that testimony about the tip was introduced to explain the course of the police investigation rather than for its truth, and therefore counsel was not constitutionally deficient for failing to object. The court also found no unreasonable application of Strickland v. Washington given the substantial evidence supporting the convictions.

Because the federal court failed to apply AEDPA’s deferential standard, the 4th Circuit reversed the order granting habeas relief.

The 26 page opinion is Langford v. Stonebreaker, Lawyers Weekly No. 001-222-26.