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Dyer v. Hornbeck

Summarized by:

  • Court: 9th Circuit Court of Appeals Archives
  • Area(s) of Law: Habeas Corpus
  • Date Filed: 02-06-2013
  • Case #: 10-15044
  • Judge(s)/Court Below: Circuit Judge Sack for the Court; Circuit Judge Gould; Concurrence by Circuit Judge M. Smith

The Court affirmed the "district court鈥檚 denial of a 28 U.S.C. 搂 2254 habeas corpus petition challenging the admission of statements Dyer made to police" and "concluded that fairminded jurists could disagree as to whether Dyer was 鈥渋n custody鈥 when she made certain disputed statements," therefore the "state court鈥檚 decision . . . was not an unreasonable application of the Supreme Court鈥檚 decision in Miranda v. Arizona, 384 U.S. 436 (1966), and its progeny."

Stacy Dyer, convicted of first degree felony murder, second degree robbery, and kidnapping, appealed from the Eastern District of California US District Court鈥檚 denial of 鈥渉er 28 U.S.C. 搂2254 petition for a writ of habeas corpus.鈥 Some information used at earlier trial was from an interview at a police station, to which Dyer had agreed to travel with the detectives in a police car from her home, during which Dyer had been allowed 鈥渦naccompanied breaks to the restroom,鈥 and prior to starting, an officer told Dyer that she was not under arrest or in trouble and could leave at any time. 鈥淭he Court of Appeal affirmed the trial court鈥檚 finding that Dyer was not 鈥渋n custody鈥 at the time she made the relevant statements, and that Miranda therefore did not apply.鈥 The Court reviewed the district court鈥檚 decision de novo and considered 鈥渨hether a 鈥渞easonable innocent person in such circumstances鈥 would understand that she could refuse to answer officers鈥 questions and leave,鈥 by examining the circumstances surrounding the interrogation and by determining whether there was a 鈥渇ormal arrest or restraint on freedom of movement.鈥 The Court determined that the appellate court鈥檚 findings that 鈥渁 reasonable innocent person in Dyer鈥檚 position would have understood herself to be free to ignore the detectives鈥 inquiries and leave鈥 were objectively reasonable. Although the Court was troubled by the decisions by the courts below, it was bound by the Antiterrorism and Effective Death Penalty Act which provides that 鈥渉abeas relief is appropriate only to remedy a state court鈥檚 鈥渦nreasonable application of鈥 clearly established Supreme Court precedent.鈥 The Court held 鈥渢hat [because] fairminded jurists could disagree as to whether Dyer was 鈥渋n custody鈥 when she made the statements in dispute, we affirm the district court鈥檚 denial of Dyer鈥檚 application for habeas relief.鈥 AFFIRMED.

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