Zaire Paige v. Stewart Eckert

Summary

Habeas corpus petition under 28 U.S.C. § 2254 challenging conviction after defendant was ejected from trial for disruptive conduct and denied readmission. The Second Circuit affirmed denial of relief, holding that the state court's application of *Illinois v. Allen* was not unreasonable under AEDPA: the trial court acted within its discretion in initially removing the defendant and in refusing to readmit him based on his pattern of delaying tactics and failure to satisfactorily demonstrate future decorum. The court also held that there is no clearly established federal right for an excluded defendant to observe trial via closed-circuit video, so the state court's denial of that accommodation did not warrant habeas relief.

Holdings

1. The Appellate Division did not unreasonably apply clearly established federal law when it affirmed the trial court's ejection and continued exclusion of Paige, because the trial court acted within its broad discretion under Allen, and the state court's factual determinations were reasonable.
2. The Supreme Court has never held that an excluded defendant has a right to observe his trial through alternative mechanisms. Therefore, the Appellate Division did not unreasonably apply clearly established federal law in affirming the denial.

Questions Presented

1. Whether the Appellate Division's decision affirming the trial court's ejection and continued exclusion of Paige from the trial was an unreasonable application of Illinois v. Allen.
2. Whether the trial court's denial of Paige's request to observe the trial via closed-circuit video violated his constitutional right to be present.

Disposition

affirmed