Robert Woodall v. Thomas Simpson
685 F.3d 574
6th Cir.2012Background
- Woodall, a Kentucky prisoner under a death sentence, pled guilty to capital murder, capital kidnapping, and first-degree rape.
- During a penalty phase, Woodall did not testify and requested a no-adverse-inference instruction; the judge denied the request.
- The jury recommended death for murder and life terms for kidnapping/rape; the Kentucky trial court adopted these recommendations.
- Woodall challenged on habeas review: (1) denial of Fifth Amendment no-adverse-inference instruction, (2) Batson/jury-selection issue, (3) other mitigating issues; district court granted relief on the instruction claim.
- The district court held the instruction denial violated Woodall’s Fifth Amendment rights and that the error was not harmless beyond a grave doubt; the Sixth Circuit affirmed, remanding for conditional grant of the writ.
- The Kentucky Supreme Court had previously rejected Woodall’s claims, and AEDPA review governs deference to that decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Woodall was entitled to a no-adverse-inference instruction at sentencing | Woodall argues Carter extends to sentencing after a guilty plea | State argues Carter does not apply here and Estelle/Mitchell do not require Carter instruction | Yes; district court erred; instruction required and error not harmless under AEDPA |
| Whether the state court unreasonably applied clearly established federal law | Woodall contends Kentucky court misapplied Carter/Estelle/Mitchell | Warden asserts proper application; decisions are reasonable | Unreasonable application under AEDPA; state court deprived Woodall of correct rule |
| Harmless-error standard applicable to the sentencing-phase error | Error had substantial and injurious effect on sentence | Error was harmless due to overwhelming evidence | Grave doubt as to harmlessness; error deemed harmful and writ granted |
| Impact of Woodall's guilty plea on Carter instruction and remedy | Guilty plea does not waive Fifth Amendment protections | Plea admitted facts; Carter instruction not required | Guilty plea does not foreclose Carter rights; instruction appropriate |
| Whether district court should address Batson/jury-selection issues after AEDPA review | No extended discussion needed if core issue resolved | Breach of Batson claims review required | Not addressed on the current AEDPA-ground decision; focus remained on no-adverse-inference issue |
Key Cases Cited
- Carter v. Kentucky, 450 U.S. 288 (1981) (no-adverse-inference instruction during guilt phase upon request)
- Estelle v. Smith, 451 U.S. 454 (1981) (Fifth Amendment extends to sentencing-phase; coercive statements scenario)
- Mitchell v. United States, 526 U.S. 314 (1999) (penalty-phase adverse inference rules; guilty plea does not waive privilege in certain contexts)
- O'Neal v. McAninch, 513 U.S. 432 (1995) (grave doubt standard for habeas harmless error; clarify Brecht framework)
- Brecht v. Abrahamson, 507 U.S. 619 (1993) (harmless-error standard in habeas review)
- Doan v. Carter, 548 F.3d 449 (2008) (harmless-error considerations in certain AEDPA reviews)
- Lakeside v. Oregon, 435 U.S. 333 (1978) (discussion of potential adverse inferences in silence cases)
- Finney v. Rothgerber, 751 F.2d 858 (6th Cir. 1985) (pre-Brecht harmlessness in persistent-offender context; cited by majority)