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Name: Collins v. Runnels
Case #: 08-17299
Court: US Court of Appeals
District 9 Cir
Opinion Date: 05/05/2010

There is no clearly established U.S. Supreme Court decision that is binding on the states that requires trial severance where co-defendants present mutually antagonistic defenses. Appellant and his co-defendant were charged with murder and robbery of a convenience store owner. Prior to trial, appellant moved for severance, arguing that a joint trial would deny him a fair trial as his alibi defense would be compromised by the co-defendant’s defense that he was coerced by appellant. Citing California policy considerations favoring joint trials, the court denied the motion. At trial, evidence was presented implicating appellant in the planning and execution of the robbery. Appellant presented his alibi defense but the jury rejected it and convicted him of first degree murder and robbery. The California Court of Appeal affirmed, holding that neither federal nor state law required severance. The Ninth Circuit held that the Court of Appeal decision was not contrary to clearly established federal law. Neither Zafiro v. United States (1993)506 U.S. 534, nor U. S. v. Lane (1986) 474 U.S. 438, cited by appellant, establish a constitutional standard binding on the states that requires severance where defendants present mutually antagonistic defenses.