Felicia Aries Morgan v. Kristine Krenke
232 F.3d 562, 2000 WL 1690175, 2000 U.S. App. LEXIS 28641 (2000)
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Rule of Law:
Under the Antiterrorism and Effective Death Penalty Act (AEDPA), a federal court may not grant habeas relief on a state court's exclusion of mental health evidence during the guilt phase of a bifurcated trial unless the state court's decision was an unreasonable application of clearly established Supreme Court precedent regarding the right to present a defense, particularly when the state has a long-standing policy of skepticism toward such evidence.
Facts:
- In October 1991, 17-year-old Felicia Morgan and two friends engaged in a 15-minute crime spree on Milwaukee's north side, committing several armed robberies.
- During one robbery, victim Brenda Adams refused to give up her leather trench coat.
- Felicia Morgan then shot and killed Brenda Adams and subsequently took the coat.
- Felicia Morgan claimed she suffered from Post-Traumatic Stress Disorder (PTSD) and Brief Reactive Psychosis, and that events just prior to the murder triggered a trance-like state consistent with PTSD.
- Felicia Morgan sought to present expert psychiatric evidence about her condition, lay testimony regarding 17 specific traumatic incidents from her past (including her father shooting at her mother when Morgan was 3), and her own testimony that she was in a trance-like state when she killed Adams, to cast doubt on her specific intent.
Procedural Posture:
- Felicia Morgan entered pleas of not guilty and not guilty by reason of mental disease or defect in a Wisconsin state trial court (Circuit Judge Michael D. Guolee).
- In the guilt phase of her bifurcated trial, the jury convicted Morgan of first-degree intentional homicide while armed, five counts of armed robbery, and one count of attempted armed robbery.
- In the responsibility phase, the jury rejected Morgan's plea of not guilty by reason of mental disease or defect.
- Morgan was sentenced to a life term on the homicide and assorted other terms on the robberies.
- The Wisconsin Court of Appeals upheld Morgan's convictions.
- The Wisconsin Supreme Court denied review of the Wisconsin Court of Appeals' decision.
- Morgan filed a petition for a writ of habeas corpus in federal district court pursuant to 28 U.S.C. § 2254.
- The federal district court granted Morgan's habeas petition, finding that the exclusion of certain evidence violated her constitutional rights.
- The State of Wisconsin appealed the federal district court's grant of habeas relief to the United States Court of Appeals for the Seventh Circuit.
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Issue:
Did the Wisconsin state courts' exclusion of expert and lay testimony regarding Felicia Morgan's mental condition during the guilt phase of her bifurcated trial constitute an 'unreasonable application' of clearly established federal law, thereby violating her constitutional rights to due process and to present a defense, warranting federal habeas relief under 28 U.S.C. § 2254?
Opinions:
Majority - Terence T. Evans
No, the Wisconsin state courts' exclusion of expert and lay testimony regarding Felicia Morgan's mental condition during the guilt phase of her bifurcated trial was not an 'unreasonable application' of clearly established federal law, and thus did not violate her constitutional rights to due process and to present a defense. The court emphasized that under AEDPA, federal courts may only grant habeas relief if a state court's decision was 'contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States,' as articulated in Williams v. Taylor. A decision is an 'unreasonable application' if the state court identifies the correct legal principle but applies it unreasonably to the facts, judged by an objective standard. The court found that Wisconsin's bifurcated trial system, which generally excludes psychiatric testimony regarding a defendant’s capacity to form intent from the guilt phase due to the state's long-standing skepticism about its reliability (established in cases like Steele and Flattum), is constitutional. Citing Montana v. Egelhoff, the court reiterated that states have broad power to define crimes and establish evidentiary procedures, and a defendant's right to present evidence is not absolute. Wisconsin's mistrust stems from its belief that the causal link between mental disease and specific intent at the precise moment a crime is committed is not sufficiently strong or reliable, especially for conditions like PTSD where symptoms are often triggered rather than persistent. The court concluded that it was not objectively unreasonable for the Wisconsin Court of Appeals to affirm the trial judge's exclusion of Morgan's evidence, as it closely resembled the type of ultimate opinion evidence on capacity to form intent that Wisconsin law prohibits in the guilt phase. Furthermore, the court rejected Morgan's claim that she was 'effectively precluded' from testifying, noting that she had no right to present irrelevant evidence to bolster her own testimony.
Analysis:
This case significantly clarifies the deferential standard for federal habeas review of state court evidentiary rulings under AEDPA. It underscores that federal courts are not to act as 'super appellate courts' for state law issues, but rather must find an 'objectively unreasonable' application of clearly established Supreme Court precedent. The ruling affirms the states' broad authority to define crimes and implement their own criminal trial procedures, including restrictions on mental health testimony during the guilt phase of a bifurcated trial, so long as these restrictions are grounded in legitimate state policy and do not unequivocally violate a defendant's fundamental due process rights. The decision highlights the difficulty of challenging state evidentiary rules in federal court unless the state court's decision is clearly beyond the bounds of reasoned judgment.
