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Name: Middleton v. McNeil
Case #: 03-1028
Court: US Supreme Court
District USSup
Opinion Date: 05/03/2004

The state court did not unreasonably apply federal law to the finding that there was no reasonable likelihood that the jury was misled by a faulty instruction. The defendant here raised a defense of battered women’s syndrome at her murder trial in California, and in instructing the jury under CALJIC 5.17, the court erroneously included a “reasonable person” standard that is not part of the instruction. The prosecutor’s closing argument included the proper instruction, and the state Court of Appeal held that it was not reasonably likely that the jury was misled by the improper instruction. The Supreme Court reversed the Ninth Circuit’s granting of habeas relief, noting that not every ambiguity or inconsistency in a jury instruction amounted to a due process violation. The relevant question was whether the improper instruction so infected the entire trial that the resulting conviction violated due process. Here, the Ninth Circuit’s review of this issue failed to give due deference to the state court finding that the instruction was not reasonably likely to have misled the jury.