Parker v. Matthews (SCOTUS 2012), 567 U.S. 37

Summary

In a per curiam opinion, the Supreme Court granted certiorari and reversed the Sixth Circuit's judgment, which had set aside Matthews' two 1981 murder convictions and instructed that habeas relief be granted under 28 U.S.C. § 2254. The Court held that the Kentucky Supreme Court's rejection of Matthews' extreme-emotional-disturbance sufficiency challenge was controlling under AEDPA: the jury instructions kept the burden of disproving disturbance with the Commonwealth, ample circumstantial evidence belied the claim, and the state court's reliance on a questionable Wellman-derived ground was immaterial once a sufficient ground existed. The Court further concluded that the prosecutor's closing remarks fell short of the Darden due-process threshold and that the Sixth Circuit wrongly treated its own circuit precedents, including a pre-AEDPA decision, as 'clearly established Federal law.' No separate writings accompanied the opinion.

Holding

Whether the Kentucky Supreme Court impermissibly shifted to Matthews the burden of proving extreme emotional disturbance and thereby relieved the Commonwealth of proving its absence beyond a reasonable doubt.. No. The jury instructions required the jury to find beyond a reasonable doubt that Matthews had not acted under the influence of extreme emotional disturbance; the case was submitted with the burden assigned to the Commonwealth, the jury found that burden carried, and the Kentucky Supreme Court found the evidence adequate to sustain that finding. Because that ground was sufficient to reject the claim, the court's additional reliance on the Wellman formulation—a ground of questionable validity—was irrelevant.

Whether the Kentucky Supreme Court's rejection of Matthews' claim that the evidence insufficiently proved he acted in the absence of extreme emotional disturbance was objectively unreasonable under AEDPA.. No—the rejection is controlling in this federal habeas proceeding. Ample evidence belied the disturbance claim, including borrowing money for the gun the day of the murders, waiting hours before going to the home, delaying between the two shootings, hiding the gun, cleaning his clothes, and giving police a false statement; and the jury could reasonably have found Dr. Chutkow's described symptoms inadequate to meet Kentucky's statutory standard requiring a reasonable explanation or excuse judged from the viewpoint of a person in the defendant's situation.

Whether the prosecutor's closing-argument remarks so infected the trial with unfairness as to make the conviction a denial of due process.. No. The prosecutor immediately and expressly disavowed any suggestion of collusion; his emphasis on Matthews' motive to exaggerate exculpatory facts is not prohibited by any precedent of this Court; and even if the 'defense of last resort' comment directed the jury to inappropriate considerations, the Kentucky Supreme Court's rejection of the misconduct claim was not so lacking in justification as to lie beyond fairminded disagreement—the governing federal decision itself sustained a far more inflammatory closing argument.

Whether the Sixth Circuit could rely on its own precedents—including a two-step improper-and-flagrant test with four flagrancy factors and a prior circuit habeas decision—in assessing the reasonableness of the Kentucky Supreme Court's handling of the prosecutorial-misconduct claim under AEDPA.. No. Circuit precedent does not constitute 'clearly established Federal law, as determined by the Supreme Court' under § 2254(d)(1) and cannot form the basis for habeas relief; the prior circuit decision was rendered under pre-AEDPA law and did not even purport to reflect clearly established law, and the highly generalized federal standard for prosecutorial misconduct bears scant resemblance to the elaborate multistep test the Sixth Circuit employed.

Whether the Kentucky Supreme Court's statement that the prosecution need not produce negating evidence when the burden of production rests on the defendant required Matthews to disprove an element of murder beyond a reasonable doubt, contravening the federal rule against shifting the burden of persuasion.. No. The statement explicitly acknowledges that the burden of proof rests with the prosecution and merely reflects that the jury may find the prosecution's burden satisfied without negating evidence unless the defendant's evidence is so probative as to establish reasonable doubt as a matter of law—a truism. The federal decision addressed situations in which the burden of persuasion was shifted to the defendant and does not remotely show that the truism contravened clearly established federal law.

Parker v. Matthews

Summary

Holding

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