## Facts

- Frederick Daniels, a Michigan prisoner, was charged in state court with rape.
- At trial, the prosecution called the victim’s mother, Jessie Scott, as a witness.
- Scott testified that, on the morning after the alleged rape, the victim told her that she was scared because Daniels had raped her.
- Daniels objected that the testimony was inadmissible hearsay and violated the Sixth Amendment Confrontation Clause.
- The trial court admitted the mother’s testimony under Michigan Rule of Evidence 803(3), which allows certain statements reflecting a declarant’s then-existing state of mind.
- Daniels was convicted.
- After unsuccessfully pursuing relief in state court, Daniels filed a federal habeas petition under 28 U.S.C. § 2254.
- The federal district court denied the petition, and Daniels appealed to the Sixth Circuit.

## Issues

1. Whether admitting the victim’s statement to her mother (introduced through the mother’s testimony) violated the Confrontation Clause under Crawford v. Washington.
2. If a Confrontation Clause violation occurred, whether Daniels was entitled to federal habeas relief under AEDPA and, in any event, whether any error was harmless under Brecht v. Abrahamson.

## Decision

- The Sixth Circuit affirmed the district court’s denial of habeas relief.
- The court held that the victim’s statement to her mother, made in an informal setting to a private individual rather than to law enforcement, was not clearly “testimonial” within the meaning of Crawford for purposes of § 2254 review.
- The court also concluded that, even assuming constitutional error, Daniels did not show the statement had a substantial and injurious effect on the verdict under Brecht.

## Legal Principles

- Under AEDPA, a federal court may grant § 2254 relief only if the state court’s adjudication was contrary to, or an unreasonable application of, clearly established Supreme Court precedent, or was based on an unreasonable determination of the facts.
- Crawford bars admission of testimonial hearsay against a criminal defendant unless the declarant is unavailable and the defendant had a prior opportunity to cross-examine; Crawford did not supply a complete definition of “testimonial.”
- Statements made informally to private individuals, outside a formal investigative setting and without government involvement, are not clearly within Crawford’s core category of testimonial statements for federal habeas purposes.
- Even where constitutional error is assumed, habeas relief generally requires a showing that the error had a substantial and injurious effect or influence on the verdict under Brecht.

## Conclusion

The Sixth Circuit affirmed the denial of Daniels’s § 2254 petition because the state court’s admission of the victim’s statement to her mother was not an unreasonable application of Crawford’s Confrontation Clause rule on testimonial hearsay, and any assumed error did not warrant relief because Daniels failed to show harmful effect under Brecht.


Daniels v. Lafler, 192 Fed. App’x 408 (2006)