Connolly v. Roden

This case aptly illustrates the limited nature of our habeas review even in the face of an admitted constitutional error. The myriad obstacles to habeas review, especially the barricades thrown up and reinforced by Supreme Court precedent, compel us to affirm Connolly’s conviction. Although I fully concur in the Court’s judgment, I write separately to flesh out why we are powerless to intervene.

Put simply, the Supreme Court has recently reiterated that although some federal judges find the scope of habeas review to be too limited, our authority to grant the writ is circumscribed by 28 U.S.C.…