Whitton v. Dixon

Summary

The Court held per curiam that the Eleventh Circuit improperly considered post-trial DNA evidence when reviewing the Florida Supreme Court’s determination that a witness’s testimony was immaterial to the jury’s verdict. Evidence never presented to the jury could not illuminate whether the testimony influenced that verdict. The Court vacated and remanded without deciding whether the state court’s determination was reasonable on the trial evidence or whether Whitton had exhausted his claim. Justice Thomas dissented, joined by Justice Alito except as to Part III–B. Thomas argued that any appellate error was harmless because the trial evidence independently supported the denial of relief and Whitton had failed to exhaust his claim. He also criticized the Court’s priorities in granting summary relief.