Stanfield v. Clement

── Stanfield v. Clement ── Court: Court of Appeals for the Ninth Circuit Date: April 22, 2026 Category: General NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS APR 22 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT KATHERINE LEA STANFIELD, No. 25-2607 D.C. No. Petitioner - Appellant, 4:22-cv-00057-REP v. MEMORANDUM* JANELL CLEMENT, Warden, Respondent - Appellee. Appeal from the United States District Court for the District of Idaho Raymond Edward Patricco, Jr., Magistrate Judge, Presiding Submitted April 14, 2026** Portland, Oregon Before: OWENS, VANDYKE, and SUNG, Circuit Judges. Petitioner-Appellant Katherine Lea Stanfield appeals the district court’s denial of her petition for writ of habeas corpus under 28 U.S.C. § 2254. We have jurisdiction under 28 U.S.C. §§ 1291 and 2253. “We review the district court’s * This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). denial of [a] § 2254 habeas corpus petition de novo.” Tamplin v. Muniz, 894 F.3d 1076, 1082 (9th Cir. 2018) (alteration in original) (citation omitted). We affirm. In 2015, the Idaho Supreme Court concluded that the admission of Dr. Lucy Rorke-Adams’ testimony regarding her technician’s statements did not violate the Confrontation Clause. Stanfield contends that this decision involved an unreasonable application of clearly established federal law under 28 U.S.C. § 2254(d)(1). To assess a claim under § 2254(d)(1), we “first identify the relevant ‘clearly established Federal law’” and then determine whether the state court’s application of that law was unreasonable. Andrew v. White, 604 U.S. 86, 95 (2025) (quoting 28 U.S.C. § 2254(d)(1)). “Clearly established” “refers to the holdings . . . of [the Supreme] Court’s decisions as of the time of the relevant state-court decision.” Lockyer v. Andrade, 538 U.S. 63, 71 (2003) (quoting Williams v. Taylor, 529 U.S. 362, 412 (2000)). The following cases set forth the relevant clearly established federal law at the time of the Idaho Supreme Court’s decision. In Crawford v. Washington, the Supreme Court held: “Testimonial statements of witnesses absent from trial [may be] admitted only where the declarant is unavailable, and only where the defendant has had a prior opportunity to cross-examine.” 541 U.S. 36, 59 (2004). In Davis v. Washington, the Court applied the “primary purpose” test to determine whether a 2 25-2607 statement was testimonial, and it held that a caller’s statement to a 911 operator was not testimonial because it was “made . . . under circumstances objectively indicating that the primary purpose . . . [wa]s to enable police assistance to meet an ongoing emergency.” 547 U.S. 813, 822, 828, 832 (2006). In Melendez-Diaz v. Massachusetts, the Court held that an expert’s affidavit declaring that a tested substance was cocaine was testimonial because it was a declaration made for the purpose of establishing a fact at trial. 557 U.S. 305, 311 (2009). In Bullcoming v. New Mexico, the Court held that the admission of an expert witness’s “surrogate testimony” about a report wholly prepared by a different analyst violated the Confrontation Clause because the testifying analyst “could not convey what [the preparing analyst] knew or observed abou