Smith v. Aldridge

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Oklahoma charged Raye Smith with several child abuse charges stemming from the death of her two-year-old daughter, Kelsey, who died from blunt force trauma to the abdomen. Kelsey’s death, and Smith’s subsequent trial, generated substantial public interest and publicity. In the end, a jury convicted Smith of enabling child abuse. Smith moved for a new trial based on claims of juror misconduct and jurors’ exposure to information outside the courtroom. To support her contention, Smith provided affidavits from trial attendees who alleged some jurors were sleeping during the trial. Smith also claimed the out-of-court publicity tainted the verdict. Smith requested an evidentiary hearing from the Oklahoma Court of Criminal Appeals (OCCA), which granted with respect to the publicity issue, but refused on the sleeping-juror issue, finding the trial judge's statement on the issue adequately refuted the allegations. Ultimately, the OCCA denied relief. Turning to the Tenth Circuit, Smith sought habeas relief, reiterating the sleeping juror issue, and arguing she received ineffective assistance of counsel for failing to bringing the sleeping juror to the trial judge's attention. Smith also argued the trial publicity violated her rights to an impartial jury and due process. Finding that the OCCA did not base its denial of Smith's claims on an unreasonable determination of the facts, and that the OCCA's opinion was contrary to or unreasonably applied clearly established federal law, the Tenth Circuit affirmed the OCCA. View "Smith v. Aldridge" on Justia Law