Court Gave Improper Weight to Tossed Juror
(CN) - A woman who was convicted of murder only after the trial judge dismissed a contrary juror does not qualify for habeas relief, the U.S. Supreme Court ruled.
Tara Sheneva Williams had acted as the getaway driver in a 1993 liquor store robbery, during which a store owner was shot and killed. After evading capture for five years, Williams eventually stood trial for murder.
During the trial, however, the judge replaced a juror he deemed biased. The alternate and the rest of the panel then unanimously found Williams guilty of special circumstances murder and a firearm enhancement.
Though the California Court of Appeal rejected Williams' claims under the state's penal code, it did not expressly acknowledge that she had raised a Sixth Amendment violation over the replaced juror.
When William's case made it to the 9th Circuit, a three-judge panel awarded her habeas relief, finding that the decision to remove the resistant juror may have impermissibly stemmed the juror's views of the merits of the case.
In reversing that decision on Wednesday, the U.S. Supreme Court paid little attention to the juror issue itself and instead concentrated on a clause of the Antiterrorism and Effective Death Penalty Act (AEDPA) of 1996 that "sharply limits the circumstances in which a federal court may issue a writ of habeas corpus to a state prisoner whose claim was 'adjudicated on the merits in state court proceedings.'"
"This issue arises when a defendant convicted in state court attempts to raise a federal claim, either on direct appeal or in a collateral state proceeding, and a state court rules against the defendant and issues an opinion that addresses some issues but does not expressly address the federal claim in question," Justice Samuel Alito wrote for the court.
In finding that Williams had been deprived of a fair trial, the 9th Circuit failed to afford proper deference to state court decisions under AEDPA, according to the ruling. Rather, it had improperly assumed that the state courts overlooked the Sixth Amendment issue and proceeded to adjudicate it de novo.
Citing the high court's 2011 ruling in Harrington v. Richter, Alito said AEDPA requires federal courts to presume that a state court has adjuticated claims that it rejects without comment, "including a federal claim that the defendant subsequently presses in a federal habeas proceeding."
The "federal claim at issue here (a Sixth Amendment jury trial claim) must be presumed to have been adjudicated on the merits by the California courts, that this presumption was not adequately rebutted, that the restrictive standard of review set out in §2254(d)(2) consequently applies, and that under that standard respondent is not entitled to habeas relief," Alito wrote (parentheses in original).
Chief Justice John Roberts joined the decision, as did Justices Anthony Kennedy, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer, Sonio Sotomayor, and Elena Kagan.
Concurring only in judgment, Justice Antonin Scalia wrote separately to emphasize that a rebuttal cannot rely on the grounds that the federal claim was "inadvertently overlooked."
"In my view the rebuttal must consist of a showing, based on the explicit text of the court's order, or upon standard practice and understanding in the jurisdiction with regard to the meaning of an ambiguous text, that the judgment did not purport to decide the federal question," Scalia wrote (emphasis in original). "'Decided after due consideration' is not, and has never been, the meaning of the legal term of art 'decided on the merits,' and giving it that meaning burdens our lower courts with an unusual subjective inquiry that demeans state courts and will be a fertile source of litigation and delay."
Scalia slammed his colleagues for revoking habeas relief from Williams, "only after conducting its own detective work."
"This complex exercise is unnecessary," he added. "A judgment that denies relief necessarily denies - and thus adjudicates - all the claims a petitioner has raised."