Dendel v. Washington

While I agree with the majority’s resolution of the Confrontation Clause issue, I disagree with its conclusion that the Michigan state courts’ rejection of Dendel’s ineffective assistance of counsel claim “was contrary to, or involved an unreasonable application of, clearly established Federal law” — the standard state prisoners must overcome to receive habeas relief under the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”), 28 U.S.C. § 2254(d)(1). This standard “severely constrains” our review. Smith v. Anderson, 632 F.3d 277, 281 (6th Cir.2011). For ineffective assistance…