Brown v. Davenport

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Habeas Corpus
  • Date Filed: April 21, 2022
  • Case #: No. 20-826
  • Judge(s)/Court Below: GORSUCH, J., delivered the opinion of the Court, in which ROBERTS, C. J., and THOMAS, ALITO, KAVANAUGH, and BARRETT, JJ., joined. KAGAN, J., filed a dissenting opinion, in which BREYER and SOTOMAYOR, JJ., joined.
  • Full Text Opinion

A petitioner must satisfy the burdens for both the Brecht and the AEDPA tests in order to qualify for habeas relief.

Respondent was shackled during the trial where he was convicted of murder. Respondent filed a petition for habeas relief and argued that being shackled during the trial was a constitutional violation and that it had a prejudicial effect during his trial. The Sixth Circuit Court of Appeals found Respondent had met the Brecht test and therefore granted Respondent’s petition for habeas relief. On appeal, the Supreme Court reversed, holding that a habeas petitioner must satisfy the burdens of both the Brecht test and the AEDPA. The Supreme Court reasoned that the Brecht test does not encompass the AEDPA test because the Brecht test only requires only the court itself to have doubt regarding the prejudicial effect of an error, while the AEDPA requires every reasonable jurist to agree it was prejudicial. REVERSED.

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