CINCINNATI, OH – The U.S. Court of Appeals for the Sixth Circuit has upheld the denial of a habeas corpus petition filed by Andrew Maurice Randolph, a Michigan man serving a life sentence for second-degree murder, ruling there was enough evidence to support his conviction and his trial attorney wasn’t required to challenge the search that uncovered the murder weapon.
Randolph was convicted after his girlfriend’s mother was found shot to death in 2012. Police found ammunition linked to the crime in Randolph’s belongings at his father’s house, and later recovered the gun from his brother’s home. Randolph argued his lawyer was ineffective for not filing a motion to suppress the evidence, but state courts found he had no reasonable expectation of privacy in either location.
In case No. 24-1202, Randolph v. Macauley, the Sixth Circuit agreed, finding that under the Antiterrorism and Effective Death Penalty Act (AEDPA), federal courts must defer to state court decisions unless they are unreasonable. The court said the evidence was lawfully admitted and that Randolph’s attorney’s decision not to file a suppression motion was not ineffective.
The panel also rejected Randolph’s request to expand his appeal to include additional issues that had already been denied earlier by both a motions panel and the en banc court, clarifying that once such requests are denied, they cannot be reopened later during the full appeal. Judges Thapar and Mathis each issued partial concurrences, with Mathis disagreeing with the majority’s broad interpretation that prevents future panels from reconsidering similar requests.
Randolph remains incarcerated under a Michigan life sentence.
