Case Explained: Non-Argument Calendar JOSIAH ANTHONY HADLEY v. SECRETARY, DEPARTMENT OF CORRECTIONS

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-07-29 Docket: 6:23-cv-01322-RBD-RMN The eleventh-circuit affirmed the district court’s denial of habeas relief to Josiah Anthony Hadley, a Florida prisoner convicted of second-degree murder. The court addressed Hadley’s sole claim for which a certificate of appealability was granted: whether the state court unreasonably applied clearly established federal law by denying his motion to suppress statements obtained in violation of *Miranda* rights. Applying the highly deferential standard of review under 28 U.S.C. § 2254(d), the court held that the Florida trial court did not unreasonably apply Supreme Court precedent regarding custodial interrogation. The court rejected Hadley’s argument that he was in custody during two interviews on October 4, 2014, noting that while the situation was a “close call,” the state court’s determination that a reasonable person would have felt free to leave—given that Hadley was uncuffed, not arrested, and allowed to control his vehicle—was a fairminded application of the law. Regarding the October 8 interview, the court held that Hadley’s pre-custody invocation of his right to counsel did not require police to cease questioning, as there is no clearly established Supreme Court precedent extending *Miranda* protections to non-custodial settings or anticipating interrogation before custody attaches. The court further clarified that the district court erroneously relied on *Stone v. Powell*, which bars Fourth Amendment habeas claims, but affirmed the denial of relief on alternative grounds that the state court’s decision was not an unreasonable application of federal law. Consequently, Hadley’s conviction and sentence remain in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.