Brown v. Davenport, 596 U.S. 118

Ervine Davenport was convicted of first‑degree murder; during trial he sat shackled (one hand, waist, ankles) behind a "privacy screen." The trial court did not state a special need for restraints on the record.
On direct appeal Michigan Supreme Court found a Deck v. Missouri violation and remanded under Chapman v. California for the trial court to determine whether the shackling error was harmless beyond a reasonable doubt.
On remand the trial court held an evidentiary hearing; all 12 jurors testified the shackling did not influence their verdicts and the court found the error harmless. Michigan Court of Appeals affirmed; Michigan Supreme Court denied leave.
Davenport sought federal habeas relief. The district court denied relief under AEDPA §2254(d). A divided Sixth Circuit reversed, applying only Brecht v. Abrahamson (harmless‑error standard for federal habeas) and granted relief.
The Supreme Court granted certiorari to resolve a circuit split on whether satisfying Brecht alone suffices when a state court adjudicated the claim on the merits, or whether AEDPA review is also required. The Court held federal courts must apply both Brecht and AEDPA; it reversed the Sixth Circuit and upheld the state‑court harmlessness ruling as reasonable under AEDPA.

Issue	Davenport's Argument	Brown's Argument	Held
Whether a federal habeas court may grant relief based solely on Brecht when a state court adjudicated the claim on the merits	Brecht subsumes AEDPA/Chapman; if Brecht is satisfied (actual prejudice/grave doubt), AEDPA adds nothing independent	When a state court has adjudicated the claim on the merits, AEDPA §2254(d) is a statutory precondition; courts must satisfy both Brecht and AEDPA before granting relief	Both tests required: a petitioner must clear Brecht and also show the state court’s decision was contrary to or an unreasonable application of clearly established Supreme Court precedent under AEDPA §2254(d)(1)
Whether the Michigan Court of Appeals unreasonably applied Supreme Court precedent (Holbrook/Chapman) in finding the shackling harmless beyond a reasonable doubt	The state court unreasonably applied Holbrook and Chapman; juror unawareness and possible influence on degree of murder render harmlessness unreasonable	Michigan court reasonably applied Chapman: juror testimony and overwhelming evidence of guilt supported harmlessness; Holbrook does not forbid post‑trial juror testimony about actual effect	The Michigan Court of Appeals acted reasonably under AEDPA; its Chapman harmlessness determination was not an unreasonable application of clearly established federal law, so Davenport cannot satisfy §2254(d)(1)

Deck v. Missouri, 544 U.S. 622 (2005) (Due Process forbids visible shackling at trial absent a special need)
Brecht v. Abrahamson, 507 U.S. 619 (1993) (federal habeas harmless‑error standard: petitioner must show a "substantial and injurious effect or influence")
Chapman v. California, 386 U.S. 18 (1967) (on direct appeal, prosecution must prove constitutional error harmless beyond a reasonable doubt)
Fry v. Pliler, 551 U.S. 112 (2007) (AEDPA does not displace Court's equitable harmless‑error precedents; Brecht governs habeas harmlessness where appropriate)
Davis v. Ayala, 576 U.S. 257 (2015) (reaffirmed Brecht as the governing habeas standard and explained its relation to AEDPA)
Holbrook v. Flynn, 475 U.S. 560 (1986) (addressed prejudice from courtroom security measures; cautioned about relying on prospective juror speculation)
Brown v. Allen, 344 U.S. 443 (1953) (historic discussion of federal habeas scope and review of state convictions)