Supreme Court of the United States
Woods v. Donald
March 30, 2015575 U.S. 312
Summary
In a per curiam opinion, the Supreme Court granted certiorari and reversed the Sixth Circuit's affirmance of federal habeas relief for Cory Donald, whose trial attorney was briefly absent during testimony concerning a telephone-call chart among his codefendants. The Court held that the Michigan Court of Appeals' rejection of Donald's claim that the absence constituted per se ineffective assistance under Cronic was neither contrary to nor an unreasonable application of clearly established federal law under 28 U.S.C. §2254(d)(1), because no holding of the Court addresses counsel's absence during testimony about codefendants that is irrelevant within the defendant's own theory of the case. The Court expressly reserved any view on the merits of the underlying Sixth Amendment principle, confining itself to the narrow context of AEDPA habeas review.
Holding
- Whether the state-court decision was 'contrary to' clearly established federal law under §2254(d)(1).. No. Because no decision of the Court addresses whether Cronic applies to counsel's absence during testimony regarding codefendants' actions, and because circumstances merely 'similar to' precedent cannot make a state decision 'contrary to' its holdings — especially where the issue is framed at too high a level of generality — the Michigan Court of Appeals' decision was not contrary to any clearly established holding.
- Whether the state-court decision was an 'unreasonable application' of clearly established federal law.. No. Within the contours of Cronic, a fairminded jurist could conclude that a presumption of prejudice is not warranted by counsel's short absence during testimony about other defendants where that testimony was irrelevant to the defendant's theory of the case; where the 'precise contours' of a right remain unclear, state courts enjoy 'broad discretion' in adjudicating a prisoner's claims.
- Whether federal habeas relief based on Cronic is available to Donald.. No. All that matters — and all that should have mattered to the Sixth Circuit — is that the Court has not held that Cronic applies to the circumstances presented; accordingly, federal habeas relief based upon Cronic is unavailable, and the Court expresses no view on the merits of the underlying Sixth Amendment principle.
Docket 14-618
Cited authorities
- 28 U.S.C. §2254
- 110 Stat. 1214
- 28 U.S.C. §2254