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Mattei v. Medeiros

United States District Court, D. Massachusetts

June 13, 2018

ALEXANDER MATTEI, Petitioner,
v.
SEAN MEDEIROS, Respondent.

          MEMORANDUM & ORDER

          WILLIAM G. YOUNG DISTRICT JUDGE

         I. INTRODUCTION

         Petitioner Alexander Mattei (“Mattei”) is a state prisoner at the Massachusetts Correctional Institution in Norfolk. Mattei was convicted of assault with intent to rape and assault and battery in the Massachusetts County Superior Court sitting in and for the County of Essex on September 16, 2011. Mattei has filed a petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2254. He asserts two claims: (1) his rights to confrontation were violated by restrictions on the cross-examination of a substitute DNA analyst, and (2) the trial judge erred in restricting defense counsel's cross-examination of a police witness. Pet. Writ Habeas Corpus (“Pet'r's Pet.”), ECF No. 1. The respondent, Sean Medeiros (“Medeiros”) opposes the petition, arguing that the Massachusetts Appeals Court decision did not unreasonably apply clearly established federal law. Resp't's Mem. Opp'n Pet. Writ Habeas Corpus (“Resp't's Opp'n”), ECF No. 13. For the reasons discussed infra, this Court DENIES Mattei's request for a writ of habeas corpus pursuant to 28 U.S.C. § 2254.

         A. Procedural History

         On May 20, 2002, Mattei was charged with home invasion, breaking and entering with intent to commit a felony, assault with intent to rape, indecent assault and battery, two counts of assault by means of a dangerous weapon, and assault and battery. Resp't's Further Supplemental Answer (“Supp. Answer”) at 179, ECF No. 14. On April 2, 2004, Mattei was convicted of six out of seven of the offenses. Id. at 180. Mattei appealed the convictions, and in 2008, the Massachusetts Appeals Court affirmed the convictions. Id. In 2010, the Supreme Judicial Court granted further appellate review. Id. The Supreme Judicial Court vacated the convictions and remanded the case for a new trial on two grounds: (1) that expert testimony ought not have been admitted without accompanying statistical explanations, and (2) that the judge improperly limited defense counsel's cross-examination. Commonwealth v. Mattei, 455 Mass. 840, 862 (2010).

         After a second jury trial in 2011, Mattei was convicted of assault with intent to rape and assault and battery, and was acquitted of the remaining charges. Supp. Answer at 181. On appeal from that conviction, Mattei raised three claims: (1) he was deprived of an opportunity to cross-examine a substitute DNA analyst, (2) the trial judge improperly restricted defense counsel's cross-examination of a police witness and refused to give a Bowden[1] instruction, and (3) the prosecutor made several errors in her closing argument. Commonwealth v. Mattei, 90 Mass.App.Ct. 577, 578 (2016). The Massachusetts Appeals Court affirmed the convictions on October 27, 2016. Id. at 584. The Supreme Judicial Court denied further appellate review on March 6, 2017. Commonwealth v. Mattei, 476 Mass. 1112 (2017). On May 15, 2017, Mattei filed a petition under 28 U.S.C. § 2254 for writ of habeas corpus by a person in state custody. Pet'r's Pet. 1.

         II. ANALYSIS

         Mattei argues that (1) his confrontation rights were violated when a substitute DNA analyst was not sufficiently cross-examined, and (2) the trial judge erred in restricting defense counsel's cross-examination of a police witness. Pet'r's Pet. 6-8. This Court concludes that neither of these arguments are meritorious and DENIES Mattei's request for relief under 28 U.S.C. § 2254.

         A. Standard of Review

         The Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”) governs petitions for habeas corpus seeking relief from convictions in state court. See Hyatt v. Gelb, 142 F.Supp.3d 198, 202 (D. Mass. 2006). A district court may entertain an application for a writ of habeas corpus on behalf of a person in custody pursuant to the judgment of a state court only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States. 28 U.S.C. § 2254(a). Habeas relief may be granted only if the petitioner is able to show that the state adjudication

(1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States; or (2) resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.

28 U.S.C. § 2254(d).

         A state court decision is contrary to clearly established federal law under 28 U.S.C. § 2254(d) if “the state court confronts facts that are materially indistinguishable from a relevant Supreme Court precedent and arrives at a result opposite to ours.” Williams v. Taylor, 529 U.S. 362, 405 (2000). In addition, a state court decision may be an unreasonable application of federal law if it identifies the applicable governing legal rule, “but unreasonably applies it to the facts of the particular state prisoner's case.” Id. at 407.

         State court decisions are given substantial deference; the incorrectness of a state court decision does not alone warrant relief for a petitioner. Instead, relief may be granted only if the state court decision in question features “‘some increment of incorrectness beyond error' that is ‘great enough to make the decision unreasonable in the independent objective judgment of the federal court.'” Evansv.Thompson, 465 F.Supp.2d 62, 67 (D. Mass. 2006) (quoting Norton v. Spencer, 351 F.3d 1, 8 (1st Cir. 2003)), aff'd, 518 F.3d 1 (1st Cir. 2008). Put simply, if a ...


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