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Ruth Ann Veal v. Iowa Correctional Institute for Women Barbara Long, Warden
Citations: 274 F.3d 479; 2001 U.S. App. LEXIS 25962; 2001 WL 1540544Docket: 01-2067
Court: Court of Appeals for the Eighth Circuit; December 5, 2001; Federal Appellate Court
Ruth Ann Veal, convicted of first-degree murder for killing Catherine Hayes in 1993, appealed the denial of her habeas corpus petition under 28 U.S.C. § 2254 after the Iowa Supreme Court upheld her conviction in 1997. Veal claimed she was denied a fair tribunal due to post-verdict social contact between the trial judge and county attorney staff, which led to her filing a motion for recusal. A new judge presided over the new trial motion, which was denied, and Veal was sentenced to life imprisonment. The district court, while finding the judge's conduct concerning, concluded there was no evidence of actual bias affecting the trial or discretionary rulings. The Eighth Circuit Court applied the AEDPA standard, affirming that the Iowa Supreme Court's decision on Veal's due process claim did not contravene established Supreme Court law requiring a fair tribunal and lack of actual bias. The court cited precedents affirming the right to a fair trial but ultimately found no violation in Veal's case. The state court evaluated Veal's claim regarding a violation of his federal constitutional right to a fair tribunal. It concluded that the trial judge demonstrated no partiality toward the state in pretrial and trial decisions, although the court criticized the judge's post-trial interactions with prosecutors and investigators. Despite this criticism, the court maintained that the trial was fair and impartial, and the judge appropriately recused himself from future proceedings. The analysis did not contradict or unreasonably apply established federal law, as determined by the Supreme Court. The record supported the conclusion that Veal received a fair trial and that the trial judge lacked actual bias or interest in the case's outcome. Although the district court concurred with the state court's rebuke of the judge's post-trial behavior as imprudent, it affirmed that the trial was conducted fairly. Consequently, the state court's factual determinations were deemed reasonable based on the evidence. Therefore, under the Antiterrorism and Effective Death Penalty Act (AEDPA), the judgment of the district court denying habeas corpus relief was upheld.