Supreme Court of the United States
Smith v. Spisak
January 12, 2010558 U.S. 139
Summary
The Supreme Court reversed the Sixth Circuit, holding that the state court's rejection of Spisak's claims regarding jury instructions and ineffective assistance of counsel was not contrary to clearly established federal law under AEDPA. The jury instructions did not violate Mills v. Maryland, and any deficiency in counsel's closing argument did not prejudice Spisak given the overwhelming evidence of guilt and his own testimony. Justice Stevens concurred in the judgment, arguing the instructions were unconstitutional under Beck v. Alabama and counsel's argument was deficient but harmless.