Sonia R. Weidenfelder v. Justin Farris, Director

Summary

The United States District Court for the Northern District of Oklahoma denied Sonia R. Weidenfelder’s petition for a writ of habeas corpus under 28 U.S.C. § 2254. The court held that the Oklahoma Court of Criminal Appeals reasonably rejected her claims that appellate counsel was ineffective for failing to challenge the exclusion of a co-defendant’s statement and the admission of an audio recording.

Holdings

1. Weidenfelder was not entitled to habeas relief because she did not establish a reasonable probability that including a challenge to the excluded statement would have changed the result of her appeal. The statement would not reasonably have established that Spaulding acted alone or negated Weidenfelder's culpability.
2. Weidenfelder was not entitled to habeas relief because the omitted Confrontation Clause claim was meritless and the recorded statements were nontestimonial and were admitted only to provide context for Weidenfelder's responses.
3. The court denied Weidenfelder's request for an evidentiary hearing because § 2254(d) review was limited to the state-court record and she did not show that she satisfied the requirements for a hearing under § 2254(e)(2).

Questions Presented

1. Whether the Oklahoma Court of Criminal Appeals unreasonably applied Strickland in rejecting Weidenfelder's claim that appellate counsel was ineffective for failing to challenge exclusion of Spaulding's statement identifying the location of the murder weapon.
2. Whether the Oklahoma Court of Criminal Appeals unreasonably applied Strickland in rejecting Weidenfelder's claim that appellate counsel was ineffective for failing to raise a Confrontation Clause challenge to the audio recording of Spaulding's statements.
3. Whether Weidenfelder was entitled to a federal evidentiary hearing or a certificate of appealability.

Disposition

dismissed