Habeas corpus; Whether the state trial court’s rulings prevented petitioner from establishing a complete defense; Washington v Texas; Chambers v Mississippi; Ungar v Sarafite; O’Neal v Balcarcel; Ferensic v Birkett; Whether the state court unreasonably applied “clearly established” law; Application of the Antiterrorism & Effective Death Penalty Act standard; Whether the errors were “prejudicial”; Brecht v Abrahamson

[This appeal was from the WD-MI.] The court held that the Michigan trial court deprived petitioner-Chandler of his “right to present a complete defense” and the Michigan Court of Appeals “unreasonably applied the Supreme Court’s governing principles to Chandler’s case and improperly denied his constitutional claim.” Thus, it reversed the district court and granted Chandler a conditional writ of habeas corpus. He was convicted of CSC I, based primarily on the testimony of one of his foster children (A.C.). On appeal, the court considered whether Chandler was deprived of his right to present a complete defense. After reviewing key precedents, it concluded “the decisive issue at trial was the reliability of A.C.’s testimony, and Chandler’s defense hinged on challenging her credibility.” It found that preventing evidence from being offered based on discovery violation sanctions “w[as] likely inappropriate and disproportionate under the Supreme Court’s case law because of the weighty interests Chandler had at stake.” While the state appellate court determined that he “had a fair trial because he was represented by counsel[,]” the court noted that “the defendants in Chambers, Washington, and Ferensic had counsel at trial—but the mere presence of competent counsel was insufficient to render their trials fair. Thus, as this court has recognized, the Supreme Court’s case law clearly establishes that Chandler’s claim may not be defeated on the basis that he was represented by counsel at trial.” The state appellate court also determined that he “had a fair trial because defense counsel ‘presented defendant’s argument that the victim fabricated the allegations against defendant.’ . . . It is true that defense counsel tried to present Chandler’s side of the story through cross-examination—by suggesting that A.C. had a history of false allegations and had a motive to accuse Chandler of abuse. But at every step, the trial court prevented Chandler from producing any evidentiary support for his position, making his defense appear unsubstantiated and perhaps even manufactured.” The court found that his “right to present a complete defense was clearly circumscribed even more severely than in Chambers, Washington, and O’Neal” where Chandler was barred “from calling any witnesses or introducing any evidence on the most critical element of his defense—whether A.C.’s testimony was credible given her history of false allegations.” The court then applied the Brecht “actual prejudice” test and concluded that the “paucity of direct evidence inculpating Chandler on this record, coupled with the considerable excluded evidence casting serious doubt on A.C.’s credibility leaves us with grave doubt about whether Chandler’s verdict was affected by the trial court’s errors.”