Oakland County's Ax-Murdering Teacher-Housewife Receives Habeas Relief
Earlier this month, a federal judge granted Seaman's petition for Habeas Corpus. Habeas relief is considered when a convicted inmate, having exhausted her state court appeals, sues the warden of her prison in federal court on the theory she is being illegally detained by the State of Michigan in light of constitutional errors in a state court criminal proceeding.
Ms. Seaman was jury convicted of first degree murder before soon-retiring Oakland Circuit Judge John McDonald. Seven-months after her trial, Judge McDonald reduced Seaman's conviction from first to second degree murder.
Both Seaman and the prosecutor appealed. The Michigan Court of Appeals reversed the trial court and reinstated Seaman's first degree murder conviction. [The linked MCOA opinion contains a fascinating in-court colloquy about premeditation between the prosecutor and trial judge at the hearing on Seaman's motion for a new trial, beginning on page 5.]
The Court of Appeals found (by 2-1) that the trial court abused its discretion by acting as a "thirteenth juror" in reducing the conviction to second degree murder. The intermediate appellate court also held that premeditation has no set time-frame but rather, can be established in the fleeting moment that it takes to have a "second look" at an imminent homicide.
Dissenting Judge Karen Fort Hood was troubled by the apparent "disconnect" between Seaman's self defense theory and testimony regarding "battered spouse syndrome". Evidence relative to the latter theory was limited by the trial court. Judge Fort Hood also commented on what she perceived as a confusion of jury instructions on the two concepts. See the last two pages of the above link for her concise dissent.
The Michigan Supreme Court declined further review of Ms. Seaman's conviction.
With her state appellate options exhausted, Seaman turned to federal court via Habeas Corpus. In her initially successful petition, she asserted that she was denied her right to effective trial counsel, guaranteed by the Sixth Amendment to the U.S. Constitution, when Attorney Lawrence Kaluzny did not challenge a ruling by the trial court that limited the testimony of Seaman's expert on "battered spouse syndrome". [BTW: In Oakland County, you just cannot hire better trial counsel than Larry Kaluzny.] The federal judge has ordered a new trial for Seaman.
We here at the LawBlogger, however, need you to stay tuned on this one as Michigan Attorney General Mike Cox is appealing the federal district court judge's order to the U.S. Sixth Circuit Court of Appeals.