23 April 2014

Law in Plain English: White v. Woodall

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.

SCOTUSblogWhite v. Woodall

Argument: Dec 11 2013 (Aud.)

Did you know? At the Sixth Circuit, this case was known as Woodall v. Simpson because Thomas L. Simpson was the warden of the Kentucky State Penitentiary at the time the case started. Since then, Randy White has become the warden, and thus the case has been restyled as White v. Woodall.

Discussion: Woodall pled guilty to capital murder, capital kidnapping, and first-degree rape. At the penalty trial, Woodall did not testify and requested that the trial judge instruct the jury that it should not draw any adverse inference from his decision not to testify. The trial judge concluded that Woodall was not entitled to the requested instruction, determining that, by entering a guilty plea, Woodall had waived his right to be free from self-incrimination. The trial court adopted the recommendation of the jury and sentenced Woodall to death on the murder conviction and life imprisonment for the remaining convictions. His conviction was affirmed by the Kentucky Supreme Court. Woodall then filed a federal habeas petition. The Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. §2254(d)(1), requires that an application shall not be granted unless adjudication of the claim "resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States." The District Court granted based on his claim that the trial court violated his Fifth Amendment right against self-incrimination by failing to instruct the jury to draw no adverse inference from Woodall's decision not to testify, despite Woodall's request for such an instruction. A divided panel of the Sixth Circuit affirmed.

Issue: The questions before the Court are (1) whether the Sixth Circuit violated 28 U.S.C. 2254(d)(1) by granting habeas relief on the trial court's failure to provide a no adverse inference instruction even though the Supreme Court has not "clearly established" that such an instruction is required in a capital penalty phase when a non-testifying defendant has pled guilty to the crimes and aggravating circumstances; and (2) whether the Sixth Circuit violated the harmless error standard in Brecht v. Abrahamson in ruling that the absence of a no adverse interference instruction was not harmless in spite of overwhelming evidence of guilt and in the face of a guilty pleas to the crimes and aggravators.

Holding: In a 6-3 decision, the Supreme Court reversed the Sixth Circuit and ruled that because the Kentucky Supreme Court’s rejection of respondent’s Fifth Amendment claim was not objectively unreasonable, the Sixth Circuit erred in granting the writ.
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