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Name: Dyer v. Hornbeck
Case #: 10-15044
Court: US Court of Appeals
District 9 Cir
Opinion Date: 02/06/2013

State court’s denial of defendant’s motion to suppress her confession was not the result of an unreasonable application of clearly established federal law. Defendant was convicted in state court of first degree murder and other offenses. She challenged the admission of an interview as a custodial interrogation in violation of Miranda v. Arizona (1966) 384 U.S. 436. Held: Affirmed. Under AEDPA, a federal court may not grant a petition for writ of habeas corpus regarding a claim that was adjudicated on the merits in state court unless the decision was contrary to or an unreasonable application of clearly established federal law as determined by the United States Supreme Court. Here, the state court decision was not an unreasonable application of Miranda because reasonable jurists could find defendant was not in custody during her questioning. Although the finding that defendant agreed to the interview is questionable, the federal court is bound by AEDPA’s requirements. Defendant was questioned in a police station, although she was allowed unaccompanied breaks, after which she returned to the interview room. The tone of the interrogation was not coercive. An independent review of the relevant factors considered by the state court in finding defendant was not in custody confirms that this decision was objectively reasonable.