Background
Jquan Leearthur McInnis was convicted of two counts of first-degree murder for shooting a man and an infant in a car. He argued on appeal that the trial court erred by admitting a confession made after he invoked his right to remain silent. The Minnesota Supreme Court agreed the confession should have been suppressed but ruled the error was harmless beyond a reasonable doubt. McInnis then filed a petition for a writ of habeas corpus under Section twenty-eight United States Code, Section two thousand two hundred fifty-four, which was denied by the district court.
The court’s reasoning
The Eighth Circuit reviewed the case under the Antiterrorism and Effective Death Penalty Act of nineteen ninety-six. The court determined that the Minnesota Supreme Court applied the correct harmless error standard from Chapman versus California. The appellate court found that a fairminded jurist could conclude the state proved intent beyond a reasonable doubt through timing and trajectory evidence. The court noted that the confession did not relate to intent and that the defendant denied intending to kill the victim in his statements. Therefore, the admission of the confession did not contribute to the verdict.
We cannot disturb that judgment unless McInnis shows that it was so obviously wrong that its error lies beyond any possibility for fairminded disagreement.
Shinn v. Kayer, 592 U.S. 111, 118 (2020)
What it means going forward
The decision reinforces the high bar for federal habeas relief when state courts apply harmless error doctrine to constitutional violations. It confirms that strong independent evidence of intent can render the admission of a confession harmless even if the confession was obtained in violation of Miranda rights.