## Facts

- Wyon Dale Childers, an Escambia County, Florida commissioner, was convicted in Florida state court of money laundering, bribery, and unlawful compensation tied to the county’s purchase of the Pensacola Soccer Complex.
- The prosecution’s theory was that Childers paid fellow commissioner Willie Junior to secure Junior’s vote approving the purchase, with anticipated kickbacks from the seller.
- Junior entered a plea agreement providing substantial sentencing leniency and immunity conditioned on complete and truthful cooperation; the agreement allowed the State Attorney, in the State’s sole discretion, to treat Junior’s statements as incomplete or untruthful and revoke benefits.
- After a co-defendant (the seller) was acquitted, Junior gave supplemental statements that added to or altered prior accounts; the State filed a notice seeking to revoke Junior’s plea agreement based on alleged incompleteness, but the trial court did not allow revocation.
- At Childers’s trial, Junior was the State’s principal witness; the defense focused on bias and credibility and cross-examined Junior for many hours about his plea agreement, its benefits, and his supplemental statements.
- The trial court barred cross-examination about (1) the co-defendant’s acquittal and (2) the State’s attempted (but unsuccessful) revocation of Junior’s plea agreement.
- Childers argued the excluded topics were probative of Junior’s motive to tailor testimony to preserve the plea benefits after the acquittal and revocation threat.

## Issues

1. Whether the state appellate court’s affirmance constituted an “adjudication on the merits” under 28 U.S.C. § 2254(d), triggering AEDPA deference in federal habeas review.
2. Whether restricting cross-examination about the co-defendant’s acquittal and the State’s attempted revocation of the witness’s plea agreement violated the Sixth Amendment Confrontation Clause, and, if so, whether the state court’s rejection of that claim was contrary to or an unreasonable application of clearly established Supreme Court precedent.

## Decision

- The Eleventh Circuit affirmed the federal district court’s denial of Childers’s § 2254 petition.
- The court held the state appellate decision was an adjudication on the merits for AEDPA purposes, even though it discussed the claim largely through state evidentiary principles.
- Applying AEDPA deference, the court held the state court’s resolution of the Confrontation Clause claim was not contrary to, and did not unreasonably apply, clearly established Supreme Court law.
- The court emphasized that Childers had a substantial opportunity to impeach Junior regarding bias and motive through extensive cross-examination about the plea deal and its benefits; exclusion of the additional topics did not warrant federal habeas relief.

## Legal Principles

- Under AEDPA, federal habeas relief is unavailable for claims adjudicated on the merits in state court unless the decision is contrary to, or an unreasonable application of, clearly established Supreme Court law, or rests on an unreasonable factual determination.
- A state court may adjudicate a federal constitutional claim on the merits without expressly citing federal authority, so long as it resolves the substance of the claim.
- The Confrontation Clause guarantees an opportunity for effective cross-examination, not unlimited cross-examination.
- Trial courts have broad discretion to impose reasonable limits on cross-examination to prevent confusion, prejudice, or cumulative inquiry, provided the defendant retains a meaningful ability to expose a key witness’s bias and motive.

## Conclusion

The Eleventh Circuit held that AEDPA deference applied because the state appellate court resolved the substance of Childers’s Confrontation Clause challenge, and that the state court’s approval of limits on bias impeachment of the State’s principal witness fell within the range of reasonable applications of Supreme Court Confrontation Clause precedent, so federal habeas relief was properly denied.


Childers v. Floyd, 642 F.3d 953 (11th Cir. 2011)