## Facts

- Andre Anderson was charged in Louisiana state court with second-degree murder for the shooting death of Richard Holloway.
- At Anderson’s jury trial, the prosecutor questioned three witnesses—Latarsha Smith, Carlos Stewart, and Alice Stewart—about whether Anderson told them why he killed Holloway.
- Those witnesses testified that Anderson sold crack cocaine and that Anderson said he killed Holloway because Holloway stole crack from Anderson.
- The jury convicted Anderson of Holloway’s murder.
- Anderson’s conviction was affirmed on direct appeal, and Louisiana courts denied his request for postconviction relief.
- Anderson then filed a federal habeas corpus petition under 28 U.S.C. § 2254 in the United States District Court for the Western District of Louisiana.
- As a ground for habeas relief, Anderson argued that the trial court improperly allowed “other-crimes” evidence of his drug dealing even though the prosecution did not provide proper pretrial notice of its intent to use that evidence.

## Issues

1. Whether Anderson was entitled to federal habeas relief based on the admission of testimony that he sold crack cocaine and had a drug-theft motive for the killing, where he argued the prosecution failed to give proper pretrial notice under state “other-crimes” evidence rules.
2. Whether the state courts’ rejection of Anderson’s evidentiary challenge was contrary to, or an unreasonable application of, clearly established federal law, as required for relief under 28 U.S.C. § 2254(d).

## Decision

- The federal district court denied Anderson’s § 2254 petition.
- The court concluded that Anderson’s complaint about pretrial notice and admission of “other-crimes” evidence primarily raised a state-law evidentiary issue, which does not itself provide a basis for federal habeas relief.
- The court further concluded that, in the trial as a whole, admitting the drug-dealing and drug-theft motive testimony did not amount to a due process violation because it did not make the proceeding fundamentally unfair.
- The court therefore left Anderson’s state conviction in place.

## Legal Principles

- Federal habeas relief for a state prisoner is limited by AEDPA; relief may be granted only if the state-court decision was contrary to, or involved an unreasonable application of, clearly established U.S. Supreme Court precedent, or was based on an unreasonable determination of facts. (28 U.S.C. § 2254(d))
- Federal habeas courts do not grant relief for errors of state law as such; a state evidentiary ruling supports habeas relief only if it violates due process by rendering the trial fundamentally unfair.
- A challenge framed as a failure to comply with state “other-crimes” notice requirements generally remains a state-law matter unless the lack of notice or admission of the evidence so prejudiced the defense that it denied a fair trial.
- Evidence describing uncharged misconduct may be constitutionally permissible when it is tied to a non-character use such as explaining an alleged motive for the charged offense; the due process question is whether the evidence’s effect was so prejudicial that it overcame the fairness of the trial.

## Conclusion

In *Anderson v. Warden, Louisiana State Penitentiary*, the federal district court denied § 2254 relief, holding that Anderson’s objection to testimony about his drug dealing and his stated drug-theft motive did not warrant habeas relief because the complaint centered on state evidentiary procedures and, in any event, admission of the testimony did not render the trial fundamentally unfair under the deferential standards that govern federal review of state convictions.


Anderson v. Warden, Louisiana State Penitentiary, 2013 WL 1405423 (2013)