Becker v. Sec’y Pa. Dept. Corr.

The Third Circuit held that AEDPA’s deferential standard also governs the decision to issue a certificate of appealability (COA) to a habeas petitioner seeking to appeal a district court’s order to which § 2254’s deferential standard applies. Becker sought a COA to challenge the District Court’s order denying his habeas petition. After the Third Circuit determined that AEDPA’s deferential standard applied, the Court evaluated the merits of Becker’s petition. At issue was the admissibility of statements he made to police after his girlfriend was shot to death. The Court agreed “with the District Court that the state trial court’s findings on custody and invocation of the right to remain silent were not objectively unreasonable. Whether Becker was in custody during his interview and whether he invoked his right to remain silent were not free from doubt. But such close calls—decisions upon which reasonable minds might disagree—are essentially insulated from federal court reversal under AEDPA, which requires federal judges to defer to the reasonable state trial court findings on both issues.”

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