Webb v. Kapture
Docket: No. 01-1879
Court: Court of Appeals for the Sixth Circuit; April 17, 2003; Federal Appellate Court
Ronald Webb appeals the district court's denial of his habeas corpus petition under 28 U.S.C. § 2254. Webb was found not guilty by reason of insanity for the second-degree murder of his father and guilty but mentally ill for the second-degree murder of his father's girlfriend. At trial, the court limited the testimony of Webb's psychiatric expert and denied his request for a jury instruction on voluntary manslaughter. The state appellate court upheld these decisions, while the Michigan Supreme Court acknowledged that the trial court's limitations on expert testimony were erroneous under Michigan's Rules of Evidence but deemed the error harmless. In his habeas petition, Webb argues that these limitations violated his Sixth Amendment right to compulsory process and due process rights, and that the refusal to instruct the jury on voluntary manslaughter breached his Fourth, Fifth, and Fourteenth Amendment rights. The district court found the Michigan Supreme Court's ruling regarding the expert testimony did not implicate the Compulsory Process Clause or deny due process. Additionally, it concluded that a refusal to instruct on voluntary manslaughter does not violate due process in non-capital cases unless it contradicts state law, which the state appellate court determined was not the case here. The district court concluded that the state courts' decisions were neither contrary to nor an unreasonable application of established federal law. After reviewing the record and applicable law, the appellate court agrees with the district court's conclusions and affirms its judgment, stating that a detailed opinion would add no value. Webb also mentioned a claim regarding a reasonable doubt instruction but did not pursue it on appeal.