Humphreys v. Emmons

Summary

Justice Sotomayor, joined by Justices Kagan and Jackson, dissents from the Supreme Court's denial of certiorari in Humphreys v. Emmons. She argues that the Eleventh Circuit's handling of a juror‑misconduct claim raises serious Sixth Amendment concerns and that the Court should vacate and remand for clarification. The dissent emphasizes that extreme juror bias should outweigh the state's no‑impeachment rule and that AEDPA deference was misapplied.