Lockyer v. Andrade

Supreme Court of the United States · 2003 · Federal Courts

Federal CourtsHabeas CorpusAEDPAEighth AmendmentAEDPA2254(d)(1)contrary tounreasonable application

Facts

Andrade stole videotapes worth about $84.70 from one Kmart store and, two weeks later, videotapes worth about $68.84 from another Kmart store. Because he had a prior petty theft conviction, the State charged the new thefts as felony petty theft with a prior conviction, and because a jury found he had prior first-degree residential burglary convictions qualifying as strikes, each theft triggered California's three strikes law. The trial court refused to reduce the charges to misdemeanors and sentenced him to two consecutive terms of 25 years to life. On direct appeal, the California Court of Appeal rejected his claim that the sentence was cruel and unusual punishment, relying on Rummel.

Issue

Whether the Ninth Circuit erred in concluding that the California Court of Appeal's decision affirming Andrade's two consecutive 25-years-to-life sentences was contrary to, or an unreasonable application of, clearly established federal law under 28 U.S.C. § 2254(d)(1). More specifically, the question was whether clearly established Supreme Court precedent required habeas relief on Andrade's Eighth Amendment gross disproportionality claim.

Rule

Under AEDPA, federal habeas relief may not be granted unless the state court decision is contrary to, or involves an unreasonable application of, clearly established Federal law as determined by the Supreme Court's holdings at the time of the state decision. In the Eighth Amendment term-of-years context, the only clearly established principle is a gross disproportionality principle whose precise contours are unclear and which applies only in the exceedingly rare and extreme case. A state court decision is not an unreasonable application merely because it is erroneous or even clearly erroneous; it must be objectively unreasonable.

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

Darnell Price is serving a recidivist sentence in Arizona for a series of low-value property felonies. After the Arizona Court of Appeals rejected his Eighth Amendment challenge in 2018, he filed a federal habeas petition arguing that broad language from several Supreme Court opinions about fairness in sentencing clearly established that his term-of-years sentence is unconstitutional.

Under § 2254(d)(1), which consideration should control the federal habeas court’s analysis?

Explanation. Section 2254(d)(1) looks only to clearly established federal law as determined by Supreme Court holdings, not dicta, and only as of the time of the relevant state-court decision. A federal habeas court therefore may not rely on broad dicta, later-decided cases, lower federal court precedent, or state court elaborations to define the governing rule. The majority identified only the Supreme Court’s holdings existing at the time of the state decision as relevant. (Derived from Lockyer v. Andrade (2003).)