context: The Supreme Court has not held that a state or federal trial court's denial of a motion to sever can, in itself, violate the Constitution.
citation_a.signal: see
citation_a.parenthetical: discussing joinder and severance in the context of Rules 8 and 14 of the Federal Rules of Criminal Procedure
citation_a.sentence: See Zafiro v. United States, 506 U.S. 534, 539, 113 S.Ct. 933, 122 L.Ed.2d 317 (1993) (discussing joinder and severance in the context of Rules 8 and 14 of the Federal Rules of Criminal Procedure); United States v. Lane, 474 U.S. 438, 446 & n. 8, 106 S.Ct. 725, 88 L.Ed.2d 814 (1986) (discussing misjoinder under Rule 8 of the Federal Rules of Criminal Procedure); see also Collins v. Runnels, 603 F.3d 1127, 1132 (9th Cir.2010) (holding that neither Zafiro nor Lane established a constitutional standard binding on the states); Runningeagle v. Ryan, 686 F.3d 758, 776-77 (9th Cir.2012) (reiterating the holding in Collins and holding that “[n]either decision is ‘clearly established Federal law’ sufficient to support a habeas challenge under § 2254”).
citation_b.signal: see also
citation_b.identifier: 603 F.3d 1127, 1132
citation_b.parenthetical: holding that neither Zafiro nor Lane established a constitutional standard binding on the states
citation_b.sentence: See Zafiro v. United States, 506 U.S. 534, 539, 113 S.Ct. 933, 122 L.Ed.2d 317 (1993) (discussing joinder and severance in the context of Rules 8 and 14 of the Federal Rules of Criminal Procedure); United States v. Lane, 474 U.S. 438, 446 & n. 8, 106 S.Ct. 725, 88 L.Ed.2d 814 (1986) (discussing misjoinder under Rule 8 of the Federal Rules of Criminal Procedure); see also Collins v. Runnels, 603 F.3d 1127, 1132 (9th Cir.2010) (holding that neither Zafiro nor Lane established a constitutional standard binding on the states); Runningeagle v. Ryan, 686 F.3d 758, 776-77 (9th Cir.2012) (reiterating the holding in Collins and holding that “[n]either decision is ‘clearly established Federal law’ sufficient to support a habeas challenge under § 2254”).