Joyner v. Barnes, 576 U.S. 1065

Two separate North Carolina capital cases: Barnes (1992 double murder during robbery) and Hurst (2002 premeditated murder during a gun sale); both juries recommended death and courts imposed death sentences.
In Barnes, a juror allegedly called a minister to ask about the death penalty generally; there was no evidence the juror discussed case facts with the minister.
In Hurst, juror Christina Foster asked her father where to find Bible passages about the death penalty; the father directed her to an "eye for an eye" passage; no evidence he knew the case or discussed trial facts.
North Carolina courts denied relief on juror-misconduct claims, finding no improper external influence on matters pending before the jury.
The Fourth Circuit reversed both denials under 28 U.S.C. §2254(d)(1), relying on its own precedents to treat religious or moral communications about the death penalty as addressing the "matter pending before the jury," and remanded for Brecht prejudice hearings.
The Supreme Court denied certiorari; Justice Thomas (joined by Justice Alito) dissented, arguing the Fourth Circuit misapplied AEDPA by relying on circuit, not Supreme Court, precedent to define clearly established federal law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a juror's consultation about the death penalty (to a minister or father) constitutes an unauthorized communication concerning "the matter pending before the jury" under Remmer	Barnes/Hurst: Such external communications implicate Remmer's presumption of prejudice because they concern the death-penalty issue the jury must decide	State/Joyner: Communications were general religious guidance, did not concern case facts or deliberations, so they did not address the matter pending before the jury	Fourth Circuit: Yes — treated death-penalty moral/spiritual discussion as the matter pending before the jury and remanded for Brecht prejudice hearings; Supreme Court denied cert but Thomas dissented criticizing that approach
Whether the Fourth Circuit properly applied AEDPA §2254(d)(1) by using circuit precedent rather than Supreme Court precedent to define "clearly established Federal law"	Barnes/Hurst: Fourth Circuit relied on its precedents to interpret Remmer and find an unreasonable state-court decision	State/Joyner: AEDPA requires deference to state-court rulings unless contrary to or an unreasonable application of Supreme Court precedent; Fourth Circuit improperly substituted its own law	Dissent (Thomas): Fourth Circuit erred by treating its own cases as "clearly established" Supreme Court law; he would have granted cert to correct the error; majority denied cert

Remmer v. United States, 347 U.S. 227 (1954) (private communications with jurors about a case are presumptively prejudicial)
Brecht v. Abrahamson, 507 U.S. 619 (1993) (standard for determining whether federal habeas relief requires reversal for nonconstitutional error affecting verdict)
Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA §2254(d) is a difficult-to-meet standard; federal courts must give deference to state-court adjudications)
Stockton v. Virginia, 852 F.2d 740 (4th Cir. 1988) (Fourth Circuit precedent concerning improper external influences on jurors)
United States v. Cheek, 94 F.3d 136 (4th Cir. 1996) (Fourth Circuit standard on unauthorized juror contact and verdict integrity)