Brown
Brown v. Runnels
Opinion
Lead Opinion
MEMORANDUM **
Petitioner Ian Charles Brown (“Petitioner”) appeals from the district court’s denial of his petition for habeas corpus. 1 We affirm.
We review the denial of a 28 U.S.C. § 2254 habeas petition de novo. Under the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”), habeas relief is appropriate only if (1) the state court’s decision was contrary to, or involved an unreasonable application of, clearly established federal law, as determined by the Supreme Court, or (2) the state court’s decision was based on an unreasonable determination of the facts. 28 U.S.C. § 2254 (d)(1) — (2).
Petitioner contends that the state trial court deprived him of his constitutional rights under the Sixth and Fourteenth Amendments when it excluded as privileged evidence regarding the extent of his brother’s mental illness. Although Petitioner’s arguments focus on the alleged constitutional harm suffered, the present AEDPA analysis focuses on whether the state court of appeal 2 reasonably applied *406 the harmless error standard when it found that Petitioner’s constitutional rights were not prejudiced by the trial court’s application of the psychotherapist-patient privilege.