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Jackie L. Henry v. Bobby Boone and Attorney General of the State of Oklahoma
Citations: 43 F.3d 1483; 1994 U.S. App. LEXIS 39761; 1994 WL 699167Docket: 94-6262
Court: Court of Appeals for the Tenth Circuit; December 13, 1994; Federal Appellate Court
Unpublished opinions may now be cited if they have persuasive value on a material issue, provided a copy is attached to the citing document or shared with the Court and parties during oral argument, as per the General Order of November 29, 1993. In the case of Jackie L. Henry v. Bobby Boone and the Attorney General of Oklahoma, the Tenth Circuit Court of Appeals has decided to resolve the appeal based on the briefs, without oral argument. Henry, convicted of first-degree murder during a robbery, sought a writ of habeas corpus after his conviction was upheld by the Oklahoma Court of Criminal Appeals. He claimed violations of his Sixth Amendment right to a fair trial and Fourteenth Amendment due process rights due to the trial judge's refusal to instruct the jury on character witness testimony and the defense of duress. The district court denied his petition after adopting a magistrate's findings. The court emphasized that a petitioner faces a significant burden when attacking a state court conviction based on jury instruction errors. Such errors must render the trial fundamentally unfair to warrant habeas relief. Henry argued that the lack of a jury instruction on character witnesses hindered the jury's consideration of favorable testimony, which he believed could have led to a not guilty verdict. However, the trial judge rejected the instruction to avoid jury confusion, and the appellate court found no rights violation, citing overwhelming evidence of guilt. Upon review, the Tenth Circuit agreed that the rejection of the character witness instruction did not result in fundamental unfairness. Character evidence was presented at trial, and Henry's attorney had the chance to argue its significance. The jury received proper instructions on presumption of innocence and reasonable doubt, thus failing to establish the necessary conditions for a successful constitutional claim. The court affirmed the lower court's denial of Henry's habeas petition. Henry asserts that the trial court's failure to provide a jury instruction on the defense of duress constituted fundamental unfairness. However, the Oklahoma Court of Criminal Appeals determined that the evidence presented at trial did not substantiate a duress defense under Oklahoma law, thereby not violating Henry's rights. Henry contests this finding, arguing that the absence of a duress instruction undermined the constitutionality of his conviction. The court disagrees, noting that the evidence may not have warranted such an instruction and that the trial court's omission did not amount to plain error. Consequently, the court concludes that there was no fundamental unfairness linked to the lack of an unsupported duress instruction, leading to the rejection of Henry's second constitutional claim. The district court's denial of Henry's habeas corpus petition is affirmed, and the mandate will be issued immediately. Additionally, it is noted that this order and judgment is not a binding precedent, with specific conditions regarding citation.