Parker v. Matthews, 132 S. Ct. 2148

Matthews murdered his mother-in-law and wife in Louisville, KY, in 1981, after buying a gun with borrowed funds; he gave a tape-recorded denial when arrested.
At trial Matthews sought a voluntary-manslaughter defense under Kentucky’s extreme emotional disturbance statute, arguing a troubled marriage and recent events supported lack of premeditation.
The Kentucky Supreme Court affirmed Matthews’ convictions and death sentence, rejecting sufficiency and misconduct claims after considering Wellman and Gall-based standards.
Matthews pursued federal habeas relief under 28 U.S.C. §2254, arguing the state court violated federal law by misallocating the burden of proof and by prosecutorial misconduct.
The district court dismissed; a divided Sixth Circuit panel reversed, granting relief on both sufficiency and prosecutorial-misconduct grounds.
The Supreme Court granted certiorari, reversed the Sixth Circuit, and remanded consistent with its opinion, clarifying AEDPA deferential review and avoiding reliance on circuit precedents

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Kentucky court’s rejection of extreme emotional disturbance was contrary to or an unreasonable application of federal law.	Matthews asserted the burden-shifting misapplied, violating Bouie/Mullaney principles.	Kentucky’s decision was reasonable given jury’s role and the evidence, including Wellman guidance.	No; Kentucky decision was reasonable under Jackson v. Virginia and AEDPA standards.
Whether prosecutorial remarks violated due process under Darden v. Wainwright.	Sixth Circuit found remarks tainted the trial by suggesting collusion and exaggeration.	Remarks, viewed in context, did not render trial unfair under Darden; any error was not clearly established.	No; Kentucky Supreme Court’s decision was not an unreasonable application of Darden.

Darden v. Wainwright, 477 U.S. 168 (U.S. Supreme Court 1986) (prosecutorial misconduct standard: improper remarks violate due process if they render trial unfair)
Bouie v. City of Columbia, 378 U.S. 347 (U.S. Supreme Court 1964) (retroactive application of judicial rulings must not be unexpected or indefensible)
Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (sufficiency of evidence: conviction supported if any rational factfinder could find elements beyond reasonable doubt)
Donnelly v. DeChristoforo, 416 U.S. 637 (U.S. Supreme Court 1974) (scope of prosecutorial conduct during closing argument in context of due process)
Gall v. Commonwealth, 607 S.W.2d 97 (Ky. 1980) (burden of producing evidence on EED and related standards in Kentucky cases)
Wellman v. Commonwealth, 694 S.W.2d 696 (Ky. 1985) (absence of extreme emotional disturbance is not an element of murder; contextual relevance to EED defense)
Mullaney v. Wilbur, 421 U.S. 684 (U.S. Supreme Court 1975) (distinguishes shifting burden of persuasion versus production; due process considerations)
Renico v. Lett, 559 U.S. _ (U.S. Supreme Court 2010) (AEDPA deference to state court factual determinations and application of standards)