Emiliano Isidro Enriquez v. R. Godwin

Summary

The United States District Court for the Eastern District of California adopted the magistrate judge’s findings and recommendations and denied Emiliano Isidro Enriquez’s petition for a writ of habeas corpus under 28 U.S.C. § 2254. The court declined to issue a certificate of appealability and directed the clerk to close the case.

Holdings

1. A claim based solely on an alleged violation of state law is not cognizable on federal habeas review under 28 U.S.C. § 2254. The court therefore denied relief on this ground.
2. The state appellate court's rejection of petitioner's sufficiency-of-the-evidence claims was not contrary to, or an unreasonable application of, clearly established Supreme Court precedent and did not involve an unreasonable determination of the facts.
3. Petitioner was not entitled to habeas relief based on the use of officers' reports and gang-expert testimony because the state court correctly identified and applied the clearly established federal law governing confrontation claims involving hearsay, and petitioner failed to demonstrate constitutional error.
4. The alleged errors concerning the jury instructions did not warrant federal habeas relief.
5. The claim concerning uncorroborated accomplice testimony did not state a cognizable federal habeas claim because it was premised on state law. To the extent it could be construed as a sufficiency-of-the-evidence claim, it still failed because a rational trier of fact could conclude petitioner was the shooter and the state court's rejection was not unreasonable under clearly established Supreme Court precedent.
6. A certificate of appealability should not issue because petitioner failed to make a substantial showing of the denial of a constitutional right and reasonable jurists would not find the denial of the petition debatable or wrong.

Questions Presented

1. Whether the claim challenging denial of the motion to set aside the Information presented a cognizable federal habeas claim.
2. Whether the state court's rejection of the sufficiency-of-the-evidence claims was contrary to, or an unreasonable application of, clearly established Supreme Court precedent or rested on an unreasonable determination of the facts.
3. Whether the use of officers' reports and gang-expert testimony violated clearly established federal confrontation or hearsay principles.
4. Whether alleged errors in the jury instructions warranted federal habeas relief.
5. Whether the claim concerning uncorroborated accomplice testimony stated a federal constitutional claim or, alternatively, demonstrated constitutionally insufficient evidence.
6. Whether a certificate of appealability should issue.

Disposition

dismissed