Adams v. Bradshaw
2016 FED App. 0138P
6th Cir.2016Background
- Stanley T. Adams was convicted in Ohio of multiple offenses including three counts of aggravated murder and was sentenced to death; direct appeal affirmed the convictions and sentence except for one vacated kidnapping count.
- At trial the court ordered Adams to wear a concealed stun belt after a hearing where jail officials cited his violent history, threats to prior counsel, and psychiatric opinions that outbursts were possible; trial counsel objected citing epilepsy risk, prejudice, and impairment of defense.
- Adams revealed during the penalty phase that he was wearing the stun belt; otherwise the court and state supreme court found the device was not visible to the jury and would not be activated absent assault or escape.
- Adams raised two certified issues on habeas: (1) whether the stun belt deprived him of a fundamentally fair trial, and (2) whether Ohio’s lethal injection protocol violated the Eighth Amendment.
- The district court denied relief on both claims; the Sixth Circuit affirmed, applying AEDPA deference and concluding (a) the stun-belt order was supported by an individualized, case-specific determination and not an unreasonable application of Supreme Court law, and (b) Adams failed to show lethal injection (or Ohio’s protocol in particular) violated clearly established Eighth Amendment precedent.
Issues
| Issue | Adams' Argument | Bradshaw's Argument | Held |
|---|---|---|---|
| Use of stun belt during trial — due process/fundamentally fair trial | Stun belt imposed constant threat, risked medical harm (epilepsy), prejudiced jury and impaired communication with counsel | Stun belt was concealed, safer than physical force, ordered after individualized hearing showing security risk | No habeas relief: Ohio courts made reasonable, case-specific findings; not contrary to Supreme Court precedent |
| Visibility and applicability of Deck (shackling rule) | Deck’s prohibition on visible restraints should bar stun-belt use in penalty phase | Device was not visible to jury (except Adams’ later statement) and pre-Deck precedent already governed visibility rule | No relief: visibility was lacking (or, even if visible during penalty remark, trial made individualized findings consistent with Deck) |
| Eighth Amendment challenge to lethal injection (method of execution) | Lethal injection causes severe physical or psychological pain; changing protocols cause mental anguish; Baze reliance misplaced | Lethal injection is not per se unconstitutional; Adams failed to show demonstrated substantial risk of severe pain or identify known, available less-risky alternative | No habeas relief: Adams failed to meet Baze/Glossip standard and did not present a cognizable, procedurally proper Eighth Amendment method claim before state courts |
| Cognizability: §2254 habeas v. §1983 for method-of-execution claims | Claim can be pursued in habeas because successful challenge could invalidate death sentence | Method/procedure challenges typically pursued under §1983; habeas limited to claims that effectively invalidate sentence | Hybrid: Court held Adams’ broad challenge to lethal injection’s constitutionality (not a discrete procedural claim) is cognizable in habeas, but procedural/implementation claims should be pursued via §1983 and discovery there |
Key Cases Cited
- Illinois v. Allen, 397 U.S. 337 (1970) (defendant may lose right to be present if disruptive; shackling/gagging disfavored except as last resort)
- Holbrook v. Flynn, 475 U.S. 560 (1986) (presence of visible security does not automatically deny fair trial; visibility and individualized necessity are key)
- Deck v. Missouri, 544 U.S. 622 (2005) (visible physical restraints require case-specific judicial determination that they are necessary)
- Baze v. Rees, 553 U.S. 35 (2008) (method-of-execution challenge requires showing a demonstrated substantial risk of severe pain compared to known, available alternatives)
- Hill v. McDonough, 547 U.S. 573 (2006) (distinguishes §1983 and habeas for some method-of-execution claims)
- Nelson v. Campbell, 541 U.S. 637 (2004) (method-of-execution claims may in some circumstances implicate habeas if they effectively invalidate sentence)
- Scott v. Houk, 760 F.3d 497 (6th Cir. 2014) (lethal injection not per se unconstitutional; discovery in §1983 may be appropriate for procedural challenges)
- Frazier v. Jenkins, 770 F.3d 485 (6th Cir. 2014) (habeas relief denied for procedural lethal-injection challenge; such claims belong in §1983)