Johnson v. Williams

Supreme Court of the United States · 2013 · Federal Courts

Federal CourtsFederal Habeas CorpusAEDPAState-Court Adjudication on the MeritsAEDPA28 U.S.C. § 2254(d)adjudicated on the meritsfederal habeas

Facts

On direct appeal, Williams argued that the trial court's questioning and dismissal of Juror 6 during deliberations violated both the Sixth Amendment and California law. The California Court of Appeal discussed the juror-dismissal issue at length, quoted United States v. Wood's definition of impartiality, and on remand also discussed People v. Cleveland, but it never expressly said it was deciding the Sixth Amendment claim. Williams did not seek rehearing on the ground that the state court had overlooked her federal claim, and later pursued federal habeas relief. The Ninth Circuit concluded that the California Court of Appeal had overlooked the Sixth Amendment issue and therefore reviewed that claim de novo.

Issue

When a state court opinion rejects some of a defendant's claims but does not expressly address a federal claim that was presented, must a federal habeas court presume that the federal claim was adjudicated on the merits for purposes of 28 U.S.C. § 2254(d)? If so, was that presumption rebutted here?

Rule

For purposes of 28 U.S.C. § 2254(d), when a federal claim has been presented to a state court and the state court denies relief in an opinion that addresses some claims but does not expressly address that federal claim, a federal habeas court must presume, subject to rebuttal in unusual circumstances, that the federal claim was adjudicated on the merits. The presumption is not irrebuttable, because § 2254(d) applies only to claims actually adjudicated on the merits, not claims rejected through sheer inadvertence.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Ohio, Devin Mercer appealed his robbery conviction, arguing that the trial judge's courtroom-security ruling violated both the Due Process Clause and an Ohio evidentiary rule. The Ohio Court of Appeals issued a reasoned opinion rejecting several of Devin's appellate arguments and analyzing the security ruling only under state cases, without expressly mentioning due process. Devin later files a federal habeas petition raising the same due process claim.

What standard should the federal habeas court apply first to determine whether § 2254(d) deference governs Devin's due process claim?

Explanation. When a federal claim was presented to the state court and the state court denied relief in an opinion addressing some claims but omitting express discussion of that federal claim, a federal habeas court must presume the federal claim was adjudicated on the merits. The omission of an express federal discussion does not itself justify de novo review. That presumption is rebuttable, but it applies at the outset. (Derived from Johnson v. Williams (2013).)