Griffin v. Warden, Chillicothe Correctional Institution

Summary

The United States District Court for the Southern District of Ohio denied Michael Griffin’s pro se motion to expand the record in his habeas corpus case. The court held that the requested Amazon purchase-history exhibit was part of the state-court record but was not necessary to decide Griffin’s claim that his conviction rested on legally insufficient evidence.

Holdings

1. Pinholster did not preclude adding the exhibit because it was part of the trial record and was seen or available to be seen by the Ohio Twelfth District Court of Appeals on direct appeal; adding it would not constitute admitting new evidence to assess the reasonableness of the state court's constitutional analysis.
2. The motion to expand the record was denied because the court did not need State's Exhibit 7J to properly decide Griffin's federal habeas claim.

Questions Presented

1. Whether the federal habeas court should expand the record under Rule 7 of the Rules Governing § 2254 Cases to include State's Exhibit 7J.
2. Whether Cullen v. Pinholster precluded consideration of the exhibit because it was not included in the state-court record filed in the federal proceeding.

Disposition

other