Heiney v. Moore: Sixth Circuit Declines to Extend the Adams “Entire-Transcript” Rule to Trial Exhibits in § 2254 Habeas Review

Introduction

Jake Paul Heiney, an orthopedic surgeon convicted in Ohio state court of two counts of gross sexual imposition and one count of tampering with records, sought federal habeas corpus relief under 28 U.S.C. § 2254. After the district court (N.D. Ohio) denied both his petition and his motion to “expand the record” with all state-trial exhibits, Heiney appealed. The Sixth Circuit granted a limited certificate of appealability focused on a single procedural question:

Did the district court err by adjudicating Heiney’s habeas petition on an incomplete record, i.e., without the physical trial exhibits?

On 13 August 2025, the Court of Appeals answered no. In doing so, it drew an explicit boundary around its earlier precedent, Adams v. Holland, 330 F.3d 398 (6th Cir. 2003). Whereas Adams obliges district courts to ensure that the state-court trial transcript is before them when ruling on a § 2254 petition, the Sixth Circuit now clarifies that the rule does not automatically extend to separately-admitted trial exhibits. Unless the petitioner can satisfy one of the recognized exceptions in Clark v. Waller, 490 F.3d 551 (6th Cir. 2007), the district court may resolve the habeas petition without procuring and reviewing those exhibits.

Summary of the Judgment

• Holding: The district court did not abuse its discretion or violate governing precedent by refusing to supplement the habeas record with the state-trial exhibits; therefore, its denial of Heiney’s § 2254 petition is affirmed.
• Key Point of Law: The Sixth Circuit declines to read Adams as imposing a per se duty on district courts to obtain and review every physical exhibit from the state proceedings. The “entire-transcript” requirement remains cabined to what Adams actually said—trial transcripts.
• Analytical Framework Applied: Adams (entire-transcript rule) → limited by Nash / Kraus (only relevant parts) → clarified and bounded by Clark (two exceptions: inaccurate factual summary or evidentiary gap). The panel held neither exception was satisfied.
• Result: Certificate of appealability issue resolved adversely to petitioner; case closed.

Analysis

Precedents Cited and Their Influence

1. Cullen v. Pinholster, 563 U.S. 170 (2011)
   – Limits § 2254(d)(1) review to the record before the state court.
   – Underscored the impropriety of federal record-expansion absent exceptions in § 2254(e)(2).
2. Adams v. Holland, 330 F.3d 398 (6th Cir. 2003)
   – Announced that district courts “must review the entire state-court trial transcript.”
   – Frequently cited but gradually narrowed by later Sixth Circuit cases.
3. Nash v. Eberlin, 437 F.3d 519 (6th Cir. 2006); Kraus v. Taylor, 715 F.3d 589 (6th Cir. 2013)
   – Clarified that only the relevant portions of the transcript need be reviewed.
4. Clark v. Waller, 490 F.3d 551 (6th Cir. 2007)
   – Created two practical exceptions permitting district courts to proceed without full transcripts:
   1. The petitioner disputes the state court’s factual summary;
   2. The petitioner identifies a gap in the evidence relied upon by the state court.
5. Hopson v. Horton, 838 F. App’x 147 (6th Cir. 2020)
   – Observed that no published case has yet extended Adams to physical exhibits.
6. Jeffries v. Morgan, 522 F.3d 640 (6th Cir. 2008)
   – Provides the standard of review: de novo for legal issues, clear-error for factual ones.

Legal Reasoning of the Court

1. Threshold Inquiry: Scope of Adams
   • The panel confirmed that Adams demands only the trial transcript, not every exhibit.
   • Extending the rule to exhibits would be an “expansion” inconsistent with Sixth Circuit precedent.
2. Application of Clark Exceptions
   • Exception 1 – Inaccurate factual summary: Heiney pointed to no concrete misstatement by the Ohio Court of Appeals (OCOA). Mere disagreement with the OCOA’s interpretation of those facts is not enough.
   • Exception 2 – Evidentiary gap: The crucial substance of the exhibits (medical records, interviews, audit logs) was already reflected in the transcript and OCOA opinion. Hence, no gap existed.
3. Discretion & AEDPA Deference
   • Even if trial exhibits were missing, the district court’s decision is reviewed for abuse of discretion, which the panel did not find.
   • AEDPA’s deferential standard bolstered the district court’s reliance on state-court factual findings.

Impact on Future Litigation

• Procedural Economy — District courts in the Sixth Circuit may deny motions to supplement § 2254 records with state-court exhibits unless a Clark exception is squarely met.
• Strategic Guidance for Petitioners — Habeas petitioners must:
  • Identify specific factual inaccuracies in the state opinion; or
  • Demonstrate that omitted materials fill a genuine evidentiary gap.
  Blanket assertions that “the record is incomplete” will not suffice.
• Clarification of Precedent — The decision tempers any lingering misconception that Adams is an unfettered mandate to scour every piece of evidence from the state trial.
• Potential En Banc / Supreme Court Review — Judge Readler’s concurrence questions the soundness of Adams itself, hinting at possible future re-examination of the “entire-transcript” command.

Complex Concepts Simplified

• Habeas Corpus (28 U.S.C. § 2254)
  A federal procedure allowing state prisoners to challenge their custody on federal constitutional grounds, after exhausting state remedies.
• Certificate of Appealability (COA)
  A jurisdictional gateway. A federal appellate court must grant a COA on a specific issue before reviewing a habeas decision.
• AEDPA Deference
  Under 28 U.S.C. § 2254(d), federal courts may not grant habeas relief unless the state-court decision was (1) contrary to, or (2) an unreasonable application of, clearly established Supreme Court precedent, or (3) based on an unreasonable determination of the facts.
• Record Expansion vs. Pinholster
  • Pinholster generally bars consideration of evidence not presented to the state court.
  • Rule 7 of the Habeas Rules allows limited expansion, but only within the constraints of § 2254(e)(2).
• Adams Rule
  Requires the federal district court to have, at minimum, the complete trial transcript when reviewing a habeas petition.
• Clark Exceptions
  Narrow circumstances allowing disposition without the entire transcript:
  • (a) Petitioner identifies inaccuracies in the state court’s factual summary.
  • (b) Missing portions would fill a material evidentiary gap referenced by the state court.

Conclusion

The Sixth Circuit’s published opinion in Heiney v. Moore cements an important procedural boundary in federal habeas practice: district courts are not categorically required to retrieve and review every physical or digital exhibit from the state trial record. Unless the petitioner can successfully invoke a Clark exception by pinpointing a factual inaccuracy or evidentiary gap, the “entire-transcript” obligation of Adams stops at the transcript itself. The decision thus streamlines § 2254 litigation, clarifies practitioner expectations, and sets the stage for a possible future reckoning with Adams’ longevity, as highlighted by Judge Readler’s concurrence.