Johnson v. Williams
133 S. Ct. 1088
| SCOTUS | 2013Background
- AEDPA bars federal relief for state prisoners if the claim was adjudicated on the merits in state court under §2254(d).
- This case questions when a state court's decision that addresses some claims but not a federal claim constitutes an adjudication on the merits.
- Respondent Williams was convicted of first-degree murder in California; juror 6 was dismissed for bias after questions about deliberation and nullification concerns.
- California appellate courts discussed the juror-dismissal issue under state law, citing Cleveland; they did not expressly address a Sixth Amendment (federal) claim in their opinion.
- Williams pursued state postconviction relief and then federal habeas, with the Ninth Circuit holding Williams’ Sixth Amendment claim was overlooked by the state court and applying de novo review.
- The Court held that the state court’s adjudication of Williams’ federal claim was presumed on the merits, but the presumption is rebuttable under Richter and related authorities.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether state court adjudication was on the merits | Williams contends the state court did not adjudicate the Sixth Amendment claim on the merits. | Cavazos argues the state court adjudicated the claim on the merits or implicitly addressed it. | Presumption of merits adjudication applies; not every unaddressed federal claim is non-merits |
| Whether Richter presumption is rebuttable | Richter allows rebuttal only in unusual circumstances. | State courts may overlook federal claims, which can be rebutted in federal review. | Richter presumption is rebuttable in limited circumstances; not irrebuttable |
| What constitutes 'adjudicated on the merits' under AEDPA | If the state court discussed related state/federal issues, the federal claim may be considered adjudicated. | Discussing related issues does not automatically adjudicate the federal claim on the merits. | Judgment denying relief on all claims can count as adjudication on the merits; context matters |
Key Cases Cited
- Harrington v. Richter, 131 S. Ct. 770 (U.S. 2011) (presumption of adjudication on the merits when state court denies relief)
- Wood v. United States, 299 U.S. 123 (U.S. 1936) (definition of impartiality and jury issues informing federal-right analyses)
- Coleman v. Thompson, 501 U.S. 722 (U.S. 1991) (irrebuttable state-ground bar and standard for AEDPA deference)
- Wainwright v. Sykes, 433 U.S. 72 (U.S. 1977) (adequate and independent state-ground doctrine in federal review)
- Swift v. McPherson, 232 U.S. 51 (U.S. 1914) (finality and merits considerations in judgments)
- Michigan v. Long, 463 U.S. 1032 (U.S. 1983) (federal-question requirement in appellate jurisdiction)
- Cleveland v. People, 25 Cal. 4th 466 (Cal. 2001) (state-court approach to juror nondeliberation and federal dimensions)
- Symington, 195 F.3d 1080 (9th Cir. 1999) (holding on holdout juror dismissal and federal right to a fair trial)
- Thomas, 116 F.3d 606 (2d Cir. 1997) (holdout juror decisions and federal constitutional implications)
- Brown, 823 F.2d 591 (D.C. Cir. 1987) (federal practice on juror dismissal and deliberation)