White v. Woodall

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Sentencing
  • Date Filed: April 23, 2014
  • Case #: 12-794
  • Judge(s)/Court Below: SCALIA, J., delivered the opinion of the Court, in which ROBERTS, C. J., and KENNEDY, THOMAS, ALITO, and KAGAN, JJ., joined. BREYER, J., filed a dissenting opinion, in which GINSBURG and SOTOMAYOR, JJ., joined.
  • Full Text Opinion

For a federal court to grant habeas corpus relief to a defendant, the previous state court's decision must involve an objectively unreasonable application of established federal law.

Respondent raped, slashed, and drowned a 16-year-old girl. He plead guilty to multiple crimes and was sentenced to death. At the trial court, Respondent chose not to testify at the penalty phase. Respondent appealed his sentencing because the court failed to instruct the jury not to draw any adverse inferences from his decision not to testify. The Kentucky Supreme Court affirmed the sentence, holding that the jury instruction is not required.

Respondent petitioned to the US Supreme Court and certiorari was denied. Respondent was then granted habeas relief from the Federal District Court, holding that the trial court’s failure to give the jury instruction violated Respondent’s rights against self-incrimination. The Sixth Circuit affirmed.

The US Supreme Court granted certiorari and reverses the Sixth Circuit’s decision. A no-adverse-inference instruction is not required at the penalty phase of trial. The Kentucky Supreme Court’s rejection of Respondent’s self-incrimination claim was not objectively unreasonable, so the Sixth Circuit erred in granting writ. By granting writ, the Sixth Circuit ignored the limitations of 28 U.S.C. §2254(d), which permits a court to grant habeas corpus relief if a previous state court’s decision involved an objectively unreasonable application of established federal law. The Supreme Court classifies the §2254(d) standard as “difficult to meet.”

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