In a 6-3 decision, the US Supreme Court Thursday ruled that a state prisoner must satisfy the court precedents and federal law to receive habeas relief in Brown v. Davenport. The decision impacts the standard federal courts use when deciding whether state trial courts’ constitutional errors are harmless.
Petitioner Mike Brown argued that the US Court of Appeals for the Sixth Circuit erred in granting habeas relief. Brown argued the state failed to meet the burden of proof established under Brecht v. Abrahamson and the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). In the 1993 case of Brecht, the US Supreme Court said the test for a grant of habeas relief should be determined by whether the defendant suffered actual prejudice from a state-court error. In 1996, Congress passed the AEDPA which blocked federal habeas relief from a state-court claim unless the state-court ruling was contrary to, or unreasonably applied to, clearly established federal law.
After hearing the case, the majority held that a state prisoner must meet both the Brecht test and the requirements under the AEDPA to receive a grant of habeas relief. In the majority opinion written by Justice Gorsuch, the court held:
“When a state court has ruled on the merits of a state prisoner’s claim, a federal court cannot grant habeas relief without applying both the test this Court outlined in Brecht and the one Congress prescribed in AEDPA; the Sixth Circuit erred in granting habeas relief to Mr. Davenport based solely on its assessment that he could satisfy the Brecht standard.”
Justice Kagan joined by Justice Breyer and Justice Sotomayor dissented. Kagan described the majority holding as an unnecessary barrier to habeas courts and the parties before them. According to Kagan, there is no reason to require that both tests be met when only the Brecht test matters.