Medina v. Commissioner of Correction

Syllabus

The petitioner, who previously had been convicted of capital felony and conspiracy to commit murder, appealed following the denial of his petition for certification to appeal from the habeas court's judgment denying his habeas petition. He claimed, inter alia, that the court improperly analyzed his right to autonomy claim under the auspices of Strickland v. Washington (466 U.S. 668), rather than under McCoy v. Louisiana (584 U.S. 414). Held: The habeas court did not abuse its discretion in denying the petition for certification to appeal, as the petitioner failed to demonstrate that his claim involved issues that were debatable among jurists of reason, that a court could have resolved the issues in a different manner, or that the questions were adequate to deserve encouragement to proceed further. The petitioner's assertion that the habeas court improperly analyzed his alleged violation of autonomy claim under Strickland, rather than under McCoy, was unavailing, as the court found, based on its unassailable credibil- ity determinations, that the petitioner did not make the necessary unequivo- cal demand that his defense counsel not pursue a defense of self-defense at his criminal trial, which demand was required for any freestanding McCoy claim to be successful. Argued March 23—officially released June 16, 2026