Hammonds
Hammonds v. McGrath
Opinion
lead Opinion
*689 MEMORANDUM **
California state prisoner Louie Ira Mendez Hammonds appeals the denial of his 28 U.S.C. § 2254 petition for a writ of habeas corpus. Hammonds challenges his conviction in California state court on one count of attempted first degree murder with personal use of a firearm and infliction of great bodily injury. We have jurisdiction pursuant to 28 U.S.C. § 2258 , and we affirm.
1. Trial Court’s Evidentiary Rulings
Hammonds argues that the trial court made two erroneous evidentiary rulings. “It is well settled that a state court’s evidentiary ruling, even if erroneous, is grounds for federal habeas relief only if it renders the state proceedings so fundamentally unfair as to violate due process.” Spivey v. Rocha, 194 F.3d 971, 977-78 (9th Cir.1999).
First, Hammonds claims that the trial court’s exclusion of evidence related to his third-party culpability defense violated his right to due process. Due process includes a criminal defendant’s right to “a meaningful opportunity to present a complete defense,” Crane v. Kentucky, 476 U.S. 683, 690 , 106 S.Ct. 2142 , 90 L.Ed.2d 636 (1986) (citation and internal quotations omitted), and evidence rules violate this right…