## Facts

- Tyrone Daniels was convicted in New Jersey of first-degree robbery and sentenced to 20 years’ imprisonment for a robbery at the Trump Taj Mahal Casino.
- Margaret Robertson, Daniels’s girlfriend at the time, worked at the casino as a cashier and provided Daniels with a magnetic access card that allowed entry to the casino’s cashier’s office.
- Robertson testified that she helped Daniels plan and carry out the robbery and identified Daniels as the robber.
- Tracey Smith, who was in the cashier’s office during the robbery, testified that a person approached, pointed a gun, and took a bag of money; Smith could not identify the robber.
- At trial, defense counsel did not request a special jury instruction stating that the State had to prove identification beyond a reasonable doubt; counsel’s stated reason was that Robertson knew Daniels, so the dispute was Robertson’s truthfulness, not whether she mistakenly identified a stranger.
- Before trial, at a suppression hearing, a detective testified about witness interviews and surveillance review conducted by other officers; defense counsel objected that the detective lacked personal knowledge and was relaying hearsay.
- The trial court allowed the detective’s testimony for a limited purpose—to explain how information received from other officers informed the detective’s investigative steps—rather than for the truth of the reported statements.
- Daniels’s conviction and sentence were affirmed on direct appeal, and his request for state postconviction relief was denied.
- Daniels filed a federal habeas petition under 28 U.S.C. § 2254, challenging (among other things) the absence of an identification charge, the admission of the detective’s suppression-hearing testimony, and the denial of a judgment of acquittal based on claimed insufficiency of the evidence.

## Issues

1. Whether the state courts unreasonably applied clearly established Supreme Court law in rejecting Daniels’s claims tied to the lack of a specific identification jury instruction, including related ineffective-assistance claims.
2. Whether admitting the detective’s suppression-hearing testimony about other officers’ interviews and surveillance review violated clearly established federal law (including confrontation and due process principles), or supported an ineffective-assistance claim.
3. Whether the state courts’ rejection of Daniels’s sufficiency-of-the-evidence challenge (and the trial court’s denial of a judgment of acquittal) was an unreasonable application of *Jackson v. Virginia* under § 2254(d).

## Decision

- The district court denied Daniels’s § 2254 petition in its entirety.
- On the identification-instruction claim, the court found no clearly established Supreme Court rule requiring a separate identification charge on these facts and concluded the general reasonable-doubt and burden instructions did not render the trial unfair.
- The court also rejected ineffective-assistance theories tied to the identification instruction, accepting that counsel made a reasoned tactical choice to attack Robertson’s credibility rather than focus the jury on misidentification.
- On the suppression-hearing testimony claim, the court held that admitting the detective’s testimony for a limited, non-truth purpose did not amount to a violation of clearly established federal law and did not warrant habeas relief.
- On the sufficiency claim, the court held that, viewing the evidence in the light most favorable to the prosecution, a rational juror could find Daniels guilty beyond a reasonable doubt, particularly based on Robertson’s testimony and corroborating circumstances.
- Applying AEDPA’s limits on federal review, the court concluded the state-court decisions were not contrary to, and did not unreasonably apply, clearly established Supreme Court precedent, and were not based on unreasonable factual determinations.
- The court denied a certificate of appealability.

## Legal Principles

- Federal habeas relief for a state prisoner is limited by 28 U.S.C. § 2254(d): relief may not be granted unless the state-court merits decision was contrary to, or an unreasonable application of, clearly established Supreme Court law, or rested on an unreasonable determination of the facts.
- Ineffective assistance of counsel requires deficient performance and prejudice. *Strickland v. Washington*, 466 U.S. 668 (1984). On habeas review, the combination of *Strickland* deference and § 2254(d) creates a highly deferential standard.
- A jury-instruction claim warrants federal habeas relief only when the challenged instructions (or omission) so infected the entire trial that the conviction violated due process, measured against clearly established Supreme Court law.
- State evidentiary rulings generally do not support federal habeas relief unless the ruling rendered the proceeding fundamentally unfair under the Due Process Clause.
- The Confrontation Clause is primarily concerned with testimonial statements admitted for their truth; limiting a statement to a non-truth purpose generally defeats a confrontation-based claim on habeas absent clearly established Supreme Court law to the contrary.
- Evidence is constitutionally sufficient if, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could find guilt beyond a reasonable doubt. *Jackson v. Virginia*, 443 U.S. 307 (1979). Under § 2254(d), the federal court asks whether the state court’s *Jackson* decision was objectively unreasonable.
- A certificate of appealability may issue only if the petitioner makes a substantial showing of the denial of a constitutional right. 28 U.S.C. § 2253(c).

## Conclusion

The district court denied Daniels’s habeas petition and a certificate of appealability because the New Jersey courts’ rejection of Daniels’s identification-instruction, suppression-hearing, and sufficiency claims—including related ineffective-assistance arguments—was not an objectively unreasonable application of clearly established Supreme Court law under § 2254(d).


Daniels v. Nogan, 2019 WL 4926952 (2019)