Watts
Watts v. Runnels
Opinion
Lead Opinion
MEMORANDUM **
1. The California Court of Appeal’s disposition of Appellant Darryl B. Watts’ Bruton issue on harmless error grounds was neither contrary to, nor an unreasonable application of, Supreme Court jurisprudence. See Williams v. Taylor, 529 U.S. 362, 412-13 , 120 S.Ct. 1495 , 146 L.Ed.2d 389 (2000); see also Lilly v. Virginia, 527 U.S. 116, 139-40 , 119 S.Ct. 1887 , 144 L.Ed.2d 117 (1999) (holding that Bruton issues are subject to harmless error analysis). The overwhelming evidence of Watts’ guilt bolstered the state court’s finding of no prejudice.
2. The California Court of Appeal’s decision to dispose of Watt’s juror misconduct claim on harmless error grounds was, again, neither contrary to, nor an unreasonable application of, Supreme Court jurisprudence. 1 See Rushen v. Spain, 464 U.S. 114 , 115-19 & n. 3, 104 S.Ct. 453 , 78 L.Ed.2d 267 (1983) (affirming state comet’s determination that a juror’s ex parte communication was harmless beyond a reason *593 able doubt); see also Mancuso v. Olivarez, 292 F.3d 939, 949 (9th Cir.2002) (affirming a conviction despite the receipt of extrajudicial evidence by the jury). Thus, Watts is not entitled to relief on this ground.