AEDPA

7th Circuit Court of Appeals

Case Name: Gerald Winfield v. Stephanie Dorethy, Warden

Case No.: 16-3316

Officials: WOOD, Chief Judge, FLAUM, Circuit Judge, and CONLEY, District Judge.

Focus: AEDPA

On July 25, 2000, after a four-day bench trial, Cook County Circuit Court Judge Leo E. Holt found Gerald Winfield guilty of the attempted murder of Jarlon Garrett. On direct appeal and again on post-conviction review, the Illinois appellate courts rejected Winfield’s challenges to his conviction and thirty-year prison sentence. By agreement of the parties, a federal district court later reviewed Winfield’s conviction under a less deferential standard than called for after the enactment of the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”), 28 U.S.C. § 2254(d), and granted Winfield’s petition for a writ of habeas corpus. In a motion under Federal Rule of Civil Procedure 59(e), the state then sought to reverse its concession that the pre-AEDPA standard applied, which the district court understandably denied as waived. Nevertheless, we are compelled by AEDPA case law and principles of state comity to reverse the district court’s finding of waiver.

Reversed and Remanded

Full Text

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