Habeas Corpus - What level of deference must federal courts give state court decisions under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA)?
McDaniel v. Brown
Whether, on federal habeas review, sufficiency-of-the–evidence claims under 28 U.S.C. § 2254(d)(1) permit a federal habeas court to expand the record or consider nonrecord evidence to determine the reliability of testimony and evidence given at trial.
Smith v. Spisak
Whether the Sixth Circuit contravened the directives of AEDPA, (which provides that a federal court may grant a state prisoner’s habeas petition if the state court adjudication “resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law”), when it concluded that the Ohio Supreme Court had incorrectly rejected Spisak’s jury instruction and ineffective assistance of counsel claims. The State claims that AEDPA permits habeas relief only when a state court ruling is “contrary to” “clearly established” Supreme Court precedent and that in this case, there was no clearly established Supreme Court precedent addressing the issue upon which the federal court (6 th Cir. Ct of Appeals) granted relief.
Wood v. Allen
Whether the state court’s decision was based on an unreasonable determination of the facts when it held that, during the sentencing phase of a capital case, an inexperienced defense attorney’s failure to pursue or present evidence regarding the defendant’s impaired mental functioning was a strategic decision when the record before it demonstrates otherwise. The Court also granted certiorari in
Wood to clarify whether the federal courts abdicate their judicial review function under AEDPA when a habeas court focuses only on whether there is clear and convincing evidence in the record to rebut certain findings of fact rather than determining if the state court’s decision is unreasonable in light of the entire state court record.
Beard v. Kindler
“...is a capital case with an unusual twist: the defendant appealing his sentence, Joseph Kindler, escaped twice from prison. A Pennsylvania state court held, and the state supreme court agreed, that Kindler waived his right to appeal when he fled. But the Third Circuit disagreed and affirmed the district court’s grant of habeas relief. In
Beard, the Court will consider when state courts have resolved an inmate’s claims on 'adequate grounds' such that federal courts may not review that inmate’s habeas claims. In particular, the Court will consider whether a state procedural default rule like Pennsylvania’s is 'inadequate' solely because it is discretionary” (direct quote from SCOTUSblog).
UPDATE: U.S. Supreme Court opinion available
here. The Court held that a discretionary state procedural rule is adequate to bar habeas relief.
Berghuis v. Smith
Whether the Sixth Circuit erred in concluding that the Michigan Supreme Court failed to apply “clearly established Federal law” under
28 U.S.C. § 2254 on the issue of the fair cross section requirement under Duren where the Sixth Circuit adopted the comparative-disparity test (for evaluating the difference between the numbers of African-Americans in the community as compared to the venires), which this Court has never applied and which four circuits have specifically rejected.
Back to Top