Brown v. Davenport

Brown v. Davenport
Supreme Court of the United States
Argued October 5, 2021
Decided April 21, 2022
Full case nameMike Brown, Acting Warden v. Ervine Davenport
Docket no.20-826
Citations596 U.S. 118 (more)
ArgumentOral argument
Holding
When a state court has ruled on the merits of a state prisoner’s claim, a federal court cannot grant habeas relief without applying both the test this Court outlined in Brecht v. Abrahamson, 507 U.S. 619, and the one Congress prescribed in the Antiterrorism and Effective Death Penalty Act of 1996; the Sixth Circuit erred in granting habeas relief to Mr. Davenport based solely on its assessment that he could satisfy the Brecht standard.
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan · Neil Gorsuch
Brett Kavanaugh · Amy Coney Barrett
Case opinions
MajorityGorsuch, joined by Roberts, Thomas, Alito, Kavanaugh, Barrett
DissentKagan, joined by Breyer, Sotomayor
Laws applied
Antiterrorism and Effective Death Penalty Act of 1996

Brown v. Davenport, 596 U.S. 118 (2022), was a case decided by the United States Supreme Court. The case concerned whether habeas relief may be granted if the Brecht v. Abrahamson test alone is satisfied, or if the application of Chapman v. California by the state courts was unreasonable because of the AEDPA.[1] The court held that federal courts can not grant habeas relief when state courts have already ruled on a prisoner's claim, unless the situation satisfies the test laid out in Brecht v. Abrahamson, and the test laid out in AEDPA.

Background

In 2008, Ervine Davenport was convicted of first-degree murder. His conviction was challenged because during his trial he had been placed in shackles. His wrists, waist, and ankles were all restrained, but there was a curtain to prevent the jury from seeing the shackles. The state said that although the shackles were unconstitutional, they did not effect the jury's verdict.[2] Michigan's Court of Appeals agreed with the state. The Michigan Supreme Court disagreed, however, after several jurors testified that they had seen the shackles or heard comments about them, and then sent the case back to the lower courts. The lower court again determined that the shackles did not affect the verdict, and the appellate court agreed with the state once again, and the Michigan Supreme Court denied an appeal.[3]

Davenport then challenged his conviction in the federal courts. The district court refused to hear the case. He then petitioned the U.S. Court of Appeals for the 6th Circuit, which agreed the hear the case. This appeals court cited the Deck v. Missouri decision, and quoted from Holbrook v. Flynn: "shackling is inherently prejudicial".[4] The court found that the state had not met the burden of proof necessary to show that the jury was not influenced by the shackling, and provided habeas relief, over the dissent of Judge Chad Readler.[3][5][6] The state attempted to have the decision stayed, but the court declined.[7]

References

  1. ^ "Brown v. Davenport". SCOTUSblog. Retrieved July 20, 2021.
  2. ^ "Court to take up case on "harmless error" standard in habeas proceedings". SCOTUSblog. April 5, 2021. Retrieved July 21, 2021.
  3. ^ a b "Brown v. Davenport". Oyez. Archived from the original on July 20, 2021.
  4. ^ Stranch, Jane (June 30, 2020). "Ervine Davenport v. Duncan MacLaren" (PDF). United States Court of Appeals for the 6th Circuit. 17–2267: 2 – via govinfo.gov.
  5. ^ "An important right-to-carry case, and another close look at a Sixth Circuit decision granting habeas relief". SCOTUSblog. March 31, 2021. Retrieved July 21, 2021.
  6. ^ "Kalamazoo murder conviction set aside; Ervine Davenport was shackled at trial". WWMT. Associated Press. September 19, 2020. Retrieved July 23, 2021.
  7. ^ Stranch (November 24, 2020). "ERVINE LEE DAVENPORT, Petitioner-Appellant, v. DUNCAN MACLAREN, Warden, Respondent-Appellee" (PDF). United States Court of Appeals for the 6th Circuit. 17–2267: 1–2 – via govinfo.gov.