Woods v. Medeiros

Summary

**Key Legal Topics:** Fifth Amendment privilege against self-incrimination; grand jury witness warnings; habeas corpus under 28 U.S.C. § 2254; AEDPA deference; clearly established federal law. **Holding:** The First Circuit affirmed denial of habeas relief, holding that no clearly established Supreme Court precedent requires that a grand jury witness (even a target) be warned of the privilege against self-incrimination before testimony can be used at trial. The state court's rejection of the claim was entitled to AEDPA deference, and the absence of controlling Supreme Court authority foreclosed relief.

Holdings

1. The First Circuit held that the SJC's rejection of Woods's Fifth Amendment claim was not contrary to or an unreasonable application of clearly established federal law because no Supreme Court precedent requires that grand jury witnesses be warned of their privilege against self-incrimination.
2. The First Circuit held that the SJC addressed Woods's Fifth Amendment claim on the merits, as evidenced by the SJC's discussion of the claim in Woods I and Woods II, and that Woods failed to overcome the presumption of merits adjudication.

Questions Presented

1. Whether the admission of Woods's grand jury testimony, given without warning of his privilege against self-incrimination, violated his Fifth Amendment rights.
2. Whether the SJC addressed Woods's federal claim on the merits, and whether its decision was contrary to or an unreasonable application of clearly established federal law.

Disposition

affirmed