Background
Timothy Boyle was convicted of capital murder for the death of a two-year-old child and sentenced to death. He appealed the denial of his habeas corpus petition, arguing that jury instructions on intent violated due process by allowing conviction based on intent to engage in conduct rather than specific intent to kill. The Eleventh Circuit granted a certificate of appealability on this single issue.
The court’s reasoning
The court reviewed the jury instructions as a whole and found they explicitly required the specific intent to cause death. The court determined there was no reasonable likelihood the jury applied the instructions improperly. The court also noted that the state court’s plain error review was entitled to deference under the Antiterrorism and Effective Death Penalty Act. The court rejected Boyle’s reliance on a later case, Towles, explaining that Towles addressed different instructions and did not invalidate the instructions in Boyle’s case.
What it means going forward
The decision reinforces the high deference federal courts give to state court determinations regarding jury instructions in capital cases under AEDPA.