6th Circuit Finds Prosecutorial Misconduct in Death Penalty Case

The Sixth Circuit affirmed in part and reversed in part a decision involving a writ of habeas corpus of a man who was sentenced for murder by the State of Kentucky.

The Sixth Circuit Court of Appeals vacated a judgment based upon claims of prosecutorial misconduct. The defendant-petitioner claimed that the prosecution had committed misconduct during their closing arguments.

Quick Facts

After two and a half years of rocky marriage, David Eugene Matthews shot his estranged wife and his mother-in-law on June 29, 1981.

He was sentenced in 1982 to a term of years for burglary and death for each of the murders.

Kentucky Supreme Court affirmed his conviction in 1985.

In 1991, the Kentucky trial court vacated the death sentence, finding error in jury instruction during the penalty phase of the trial.

The vacatur was subsequently reversed on the death penalty issue when the Commonwealth of Kentucky appealed. Defendant-Petitioner made a motion for reconsideration and was denied in 1997 and again in 1998. He tried to take it to the U.S. Supreme Court, but was denied review there as well.

So, he filed a habeas corpus writ in district court.

That writ was appealed all the way to the Sixth Circuit Court of Appeals, where he raised claims revolving largely around his extreme emotional distress and the fact that evidence of it was not included in the penalty phase of the trial.

Prosecutorial Misconduct

In the closing phase of the trial, the prosecution asserted that the defendant was colluding with his attorney and doctor and exaggerating his emotional distress. Defendant-Petitioner argued that this undermined his credibility.

The Sixth Circuit Court of Appeals said: "[T]he Commonwealth's misconduct was sufficiently egregious to render the entire trial fundamentally unfair."

As such, the comments rendered the trial unfair to the Petitioner and denied him of his constitutionally protected rights.

The Court also held that, at the time of conviction, the Commonwealth of Kentucky had a burden to disprove an extreme emotional disturbance defense.

"Convicting Petitioner of murder when the prosecution failed to prove the EED element beyond a reasonable doubt, contravened the Supreme Court's established precedent requiring the state to prove every element of a crime beyond a reasonable doubt."

Related Resources:

• Matthews v. Parker (FindLaw Cases)
• Browse Sixth Circuit Cases (FindLaw)
• Matthews v. Parker (Sixth Circuit Court of Appeals)