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Criminal Procedure Keyed to Ohlin
Tyler v. Cain
Citation:
533 U.S. 656 (2001)Facts
During a fight with his estranged girlfriend in March 1975, petitioner Melvin Tyler shot and killed their 20-day-old daughter. A jury found Tyler guilty of second-degree murder, and his conviction was affirmed on appeal. After sentencing, Tyler sought post-conviction relief. By 1986, he had filed five state petitions, all of which were denied. He next filed a federal habeas petition, which was unsuccessful as well. After this Court’s decision in Cage, Tyler continued his effort. Because the jury instruction defining reasonable doubt at Tyler’s trial was substantively identical to the instruction condemned in Cage, Tyler filed a sixth state post-conviction petition, this time raising a Cage claim.
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