Habeas Relief Denied

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7^th Circuit Court of Appeals

Case Name: Christy Lentz v. Teri Kennedy

Case No.: 18-2659

Officials: FLAUM, BARRETT, and ST. EVE, Circuit Judges.

Focus: Habeas Relief Denied

For nearly a week Christy Lentz feigned ignorance as she pretended to help investigators locate her missing father. Officers soon discovered the father’s decaying body hidden at the office building the two shared, and all signs pointed to Lentz as the murderer. Lentz, with her young daughter in tow, voluntarily accompanied officers to the police station under the pretense of follow-up questioning for the missing persons investigation. For the first hour and a half, officers asked general questions, like when and where she last saw her father, to commit Lentz to her story. They then took a cigarette break. When the interview resumed, the tone changed. The officers read Lentz her Miranda rights and confronted her with the mounting evidence against her. Over the next four hours, Lentz slowly confessed to shooting her father.

In the state trial court, Lentz moved to suppress her videotaped confession but the court denied her motion. She proceeded to trial, where the confession was admitted into evidence, and a jury found her guilty of first-degree murder. The Illinois Appellate Court affirmed the conviction on direct review. Lentz then tried her hand at state postconviction proceedings but was unsuccessful.

Now on federal habeas review, Lentz claims the interrogation violated her constitutional rights in two ways: that she was “in custody” during the pre-Miranda portion of the interview, and that her confession was involuntary. Because our review is deferential and the state court’s decision with respect to both issues was not an unreasonable application of clearly established federal law, we affirm the district court’s denial of habeas relief.

Affirmed

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Derek A Hawkins is trademark corporate counsel for Harley-Davidson. Hawkins oversees the prosecution and maintenance of the Harley-Davidson’s international trademark portfolio in emerging markets.