Justices Deny Habeas Relief to Kentucky Killer
WASHINGTON (CN) - The Supreme Court on Wednesday reversed an order of habeas relief to a Kentucky man who "brutally raped, slashed with a box cutter, and drowned a 16-year-old."
Police had found the body of 16-year-old Sarah Hansen naked and floating in a lake about a half-mile from the convenience store she had been trying to visit on the night she disappeared, Jan. 25, 1997.
Though her throat was slashed twice and her windpipe was totally severed, her actual cause of death was drowning.
Robert Woodall had pleaded guilty to capital murder, capital kidnapping and first-degree rape when "faced with overwhelming evidence of his guilt," Justice Antonin Scalia wrote for a six-member majority.
Woodall had been at the convenience store in question; his fingerprints were on Hansen's van; Hansen's blood was on his clothing and door; and his DNA matched a swab of the victim's vagina.
At the penalty phase, Woodall asked the Kentucky trial judge to instruct the jury that it should not draw any adverse inference from his decision not to testify.
The judge concluded, however, that Woodall waived his right to be free from self-incrimination by pleading guilty. He later adopted the jury's recommendations to sentence Woodall to death for the murder conviction, and two consecutive life sentences for the other charges.
Though the state courts affirmed, and the Supreme Court declined to take up his case back in 2002, a federal judge found that Woodall qualified for habeas relief on two grounds: a violation of his Fifth Amendment right against self-incrimination and a constitutional error during jury selection.
The latter violation stemmed from Kentucky use a peremptory challenge to strike a black juror jury without holding a hearing.
A three-judge panel of the 6th Circuit affirmed in July 2012, and the Supreme Court granted the state a writ of certiorari in June.
In reversing Wednesday, Scalia said the grant of habeas relief to Woodall disregarded the limitations of Section 2254(d) of Title 28, "a provision of law that some federal judges find too confining, but that all federal judges must obey."
"Because the Kentucky Supreme Court's rejection of respondent's Fifth Amendment claim was not objectively unreasonable, the Sixth Circuit erred in granting the writ," Scalia added. "We therefore need not reach its further holding that the trial court's putative error was not harmless. The judgment of the Court of Appeals is reversed, and the case is remanded for further proceedings consistent with this opinion."
Chief Justice John Roberts joined the majority, along with Justices Anthony Kennedy, Clarence Thomas, Samuel Alito and Elena Kagan.
Writing in dissent, Justice Stephen Breyer said it was fair to find that "the Kentucky courts unreasonably applied clearly established Supreme Court law in concluding that the Fifth Amendment did not entitle Woodall to a no-adverse-inference instruction."
The precedents that the state courts deemed relevant to Woodall's challenge were the 1981 decisions in Carter v. Kentucky and Estelle v. Smith, and the 1999 decision in Mitchell v. United States.
"As long as fair-minded jurists would conclude that two (or more) legal rules considered together would dictate a particular outcome, a state court unreasonably applies the law when it holds otherwise," Breyer wrote, joined by Justices Ruth Bader Ginsburg and Sonia Sotomayor.
"That is the error the Kentucky Supreme Court committed here. Failing to consider together the legal principles established by Carter and Estelle, the state court confined those cases to their facts. It held that Carter did not apply because Woodall had already pleaded guilty - that is, because Woodall requested a no-adverse-inference instruction at the penalty phase rather than the guilt phase of his trial. And it concluded that Estelle did not apply because Estelle was not a 'jury instruction case.' The Kentucky Supreme Court unreasonably failed to recognize that together Carter and Estelle compel a requested no-adverse-inference instruction at the penalty phase of a capital trial. And reading Mitchell to rein in the law in contemplation of never-before-recognized exceptions to this normal rule would be an unreasonable retraction of clearly established law, not a proper failure to 'extend' it. Because the Sixth Circuit correctly applied clearly established law in granting Woodall's habeas petition, I would affirm."