Sixth Circuit -- Marcus Middlebrook v. Robert Napel

State appeals court did not unreasonably apply relevant federal law when holding that trial court had sufficiently investigated charges of jury misconduct.  One juror was alleged to have told the others that the deft's associates were quite dangerous, and that they should watch their back.

 No Scotus precedent on premature adjudication claims, so no AEDPA basis for collateral attack.

Marcus Middlebrook v. Robert Napel