Celester v. Lynds — 1st Cir. (Nov 2, 2026)
The First Circuit considers whether a murder defendant was denied a fair opportunity to present his defense. A 1994 Massachusetts shooting killed one man and injured another. Jermaine Celester was convicted of second-degree murder at a retrial. His defense was that someone in a passing car fired the shots. Jurors heard evidence about the car and two occupants fleeing police. But the judge excluded the occupants' identities, their relationships with the victims, and conflicting accounts of their whereabouts. Celester says those details would have supported his claim that someone else was responsible. After state courts upheld his conviction, a federal judge denied his habeas petition, a challenge to the legality of his imprisonment. He now appeals that denial. His lawyer will argue that excluding the evidence undermined his only defense. The state will defend the ruling as a reasonable response to speculation. Federal habeas review is not an ordinary appeal of an evidence ruling; it gives state-court decisions substantial deference. The central question is whether the state court unreasonably applied clearly established Supreme Court law protecting the opportunity to present a defense.
Celester v. Lynds (No. 23-1973) — U.S. Court of Appeals for the First Circuit, argued November 2, 2026.
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