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December 14, 2020

Via 6-3 per curiam ruling, SCOTUS reinstates Arizona death sentence after finding Ninth Circuit "clearly violated [its] AEDPA jurisprudence"

The US Supreme Court issued this lengthy order list this morning, though much of its length comes from the Court's 13-page per curiam decision in Shinn v. Kayer, No. 19-1302 (S. Ct. Dec. 14, 2020) (available here). The Kayer case results from a murder committed more than a quarter century ago which resulted in an Arizona death sentence. The SCOTUS decision, from which Justices Breyer, Sotomayor, and Kagan dissented but without any opinion, vacates a Ninth Circuit reversal of the death sentence. Here is how the opinion begins and ends:

The Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) restricts the power of federal courts to grant writs of habeas corpus based on claims that were “adjudicated on the merits” by a state court.  28 U.S.C. §2254(d).  When a state court has applied clearly established federal law to reasonably determined facts in the process of adjudicating a claim on the merits, a federal habeas court may not disturb the state court’s decision unless its error lies “beyond any possibility for fairminded disagreement.”  Harrington v. Richter, 562 U.S. 86, 103 (2011).  In this case, the Court of Appeals erred in ordering issuance of a writ of habeas corpus despite ample room for reasonable disagreement about the prisoner’s ineffective-assistance-of-counsel claim.  In so doing, the Court of Appeals clearly violated this Court’s AEDPA jurisprudence.  We therefore grant the petition for certiorari and vacate the judgment below....

Under AEDPA, state courts play the leading role in assessing challenges to state sentences based on federal law.  A state court heard Kayer’s evidence and concluded that he failed to show prejudice.  The court below exceeded its authority in rejecting that determination, which was not so obviously wrong as to be “beyond any possibility for fairminded disagreement.” Id., at 103.  Under §2254(d), that is “‘the only question that matters.’” Id., at 102.

We grant the petition for a writ of certiorari, vacate the judgment of the United States Court of Appeals for the Ninth Circuit, and remand the case to that court for further proceedings consistent with this opinion.

December 14, 2020 at 09:50 AM | Permalink

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