20 February 2013

Law in Plain English: Johnson v. Williams

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

Johnson v. Williams

Williams was in prison for first degree murder. He appealed in state court and raised, among other things, a Sixth Amendment claim because one of the jurors had been dismissed during deliberations at his trial. The state appeals court found that the juror was properly dismissed, but did not specifically address if it was a Sixth Amendment claim. He later sought habeus relief in federal court (he was challenging the lawfulness of his imprisonment; habeus proceedings are very common among prison inmates--thousands are filed every year). The Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) says that a federal court considering a habeas petition may not grant relief to a state prisoner whose claim has already been “adjudicated on the merits in State court” (unless other conditions are met, that don't apply here, see comment). The issue in this case then is whether Williams's claim had been “adjudicated on the merits” for purposes of AEDPA where the appeals court denied relief in their decision but did not expressly acknowledge the Sixth Amendment basis for the claim. The Supreme Court ruled that when the  state appeals court ruled against Williams, the federal court considering his habeus petition should presume that his federal claim was adjudicated on the merits. The practical impact of this decision is that state prisoners filing habeus claims will have a more difficult time getting review in federal courts.
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