Eleventh Circuit Court of Appeals - Published Opinions

Friday, May 11, 2012

Mansfield: Miranda error Harmless under AEDPA

In Mansfield v. Sec. Dep’t of Corrections, No. 09-12312 (May 9, 2012),
the Court denied habeas relief to a Florida inmate sentenced to death for a 1995 murder.
At trial, a videotaped confession obtained in violation of Miranda was erroneously admitted. The Florida state courts concluded that the error was harmless.
The Court, viewing the harmless error "through the [deferential] lens of AEDPA," credited the Florida Supreme Court’s reliance on evidence in support of Mansfield’s conviction. The Court noted evidence that Mansfield went swimming shortly after committing the murder in order to wash off any blood, a mark on the victim left by Mansfield’s ring, and evidence linking Mansfield to the crime scene. This and other "substantial" evidence made the erroneous admission of the videotape harmless.