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Charles Jeremiah v. Michael Kemna
Citations: 370 F.3d 806; 2004 U.S. App. LEXIS 11075; 2004 WL 1237650Docket: 03-2809
Court: Court of Appeals for the Eighth Circuit; June 7, 2004; Federal Appellate Court
Charles Jeremiah appeals the dismissal of his habeas corpus petition after being convicted in 1999 for the murder of Shawna Roberts, receiving a life sentence and an additional 10 years for armed criminal action. His appeals in state courts were unsuccessful, leading to a 28 U.S.C. § 2254 petition in December 2002 with eight grounds for relief, all denied by the district court except for Ground 2 concerning alleged misleading jury instructions related to his intoxication. During the trial, the prosecutor stated that intoxication does not negate intent, despite the trial court’s instruction allowing consideration of intoxication in determining guilt. Jeremiah argued that the prosecutor's misinterpretation prejudiced his defense. The Missouri Court of Appeals acknowledged the prosecutor's statement was inaccurate but found no resulting prejudice when assessing the trial's totality. The Eighth Circuit Court of Appeals rejected the State's procedural default claim regarding Jeremiah's due process rights, referencing Sandstrom v. Montana, which prohibits jury instructions that potentially mislead regarding the burden of proof. Jeremiah's claim hinges on whether the Missouri Court of Appeals' review of his due process claim was contrary to or involved an unreasonable application of clearly established federal law under 28 U.S.C. § 2254(d)(1). Jeremiah contends that the state court's failure to cite federal cases means it did not adjudicate his claim on the merits, but this argument is rejected. A state court is not required to reference specific federal cases as long as it addresses the constitutional claim substantively rather than on procedural grounds. The Missouri Court of Appeals did adjudicate Jeremiah's due process claim on the merits by reviewing the prosecutor's misstatements and concluding that Jeremiah experienced no prejudice, thus no violation of his due process rights. The relevant legal standard indicates a state court's decision is contrary to Supreme Court precedent only if it applies a conflicting rule or reaches a different result on materially indistinguishable facts. In this case, the Missouri Court assessed the prosecutor's statements within the broader context of the trial and presumed the jury would follow the court's instructions. Although the prosecutor misrepresented the instruction's meaning, the court determined that these misstatements did not prejudice Jeremiah, as a reasonable juror would not have been misled regarding the burden of proof given that the jury received the correct instruction multiple times. Consequently, the judgment dismissing Jeremiah's petition is affirmed.