Taylor v. Maddox
United States Court of Appeals for the Ninth Circuit
366 F.3d 992 (2004)
Sixteen-year-old Leif Taylor (plaintiff) was arrested as a suspect in a shooting death and interrogated for over two hours; whether he was given Miranda warnings was disputed, and there was no audio or video recording of most of the interrogation. Taylor said he repeatedly asked for his mother and a lawyer and was refused, while the sole detective who testified gave vague, contradictory answers about whether Taylor made such requests. Taylor eventually waived his rights and gave a recorded confession; California charged him with murder and robbery. The trial court denied Taylor's motion to suppress the confession, crediting the detective over Taylor, and Taylor was convicted. After his petition for habeas relief under the Antiterrorism and Effective Death Penalty Act (AEDPA) was denied by the district court against warden Thomas Maddox (defendant), Taylor appealed.
Whether a federal court may overturn a state court criminal conviction under AEDPA when there is clear and convincing evidence that the state court's credibility finding about a key witness was unreasonable.