Sexton v. Beaudreaux
138 S. Ct. 2555
SCOTUS2018Background
- Beaudreaux shot and killed Wayne Drummond in 2006; two witnesses (Esho and Crowder) later identified Beaudreaux after photographic displays and in-person viewing.
- Crowder identified Beaudreaux from a yearbook and a photo lineup while in custody 17 months after the shooting; Esho made two tentative photo identifications the day after the shooting and later made a positive in‑court ID after seeing Beaudreaux in person.
- Beaudreaux was convicted of first‑degree murder in 2009; direct appeal and initial state habeas were denied. He filed a second state habeas alleging trial counsel was ineffective for failing to move to suppress Esho’s identification; the California courts denied relief summarily.
- On federal habeas, a Ninth Circuit panel reversed, holding counsel’s failure to move to suppress was deficient and prejudicial because pretrial procedures were unduly suggestive and the identification unreliable; the Ninth Circuit applied de novo review and relied on arguments not presented to the state court.
- The Supreme Court granted certiorari and reversed the Ninth Circuit, holding the court of appeals failed to apply AEDPA deference and did not consider theories that could have supported the state court’s summary denial.
Issues
| Issue | Plaintiff's Argument (Beaudreaux) | Defendant's Argument (Sexton/State) | Held |
|---|---|---|---|
| Whether counsel performed deficiently by not filing a motion to suppress Esho’s ID | Counsel’s failure was deficient because photo procedures were unduly suggestive (same photo in multiple lineups; suggestivity of prelim hearing) | Counsel reasonably declined because suppression likely would fail under totality-of-circumstances reliability analysis | Court: State court denial not unreasonable; fairminded jurist could find no deficient performance because suppression motion could have failed |
| Whether petitioner was prejudiced under Strickland absent the challenged ID testimony | Without Esho’s ID, conviction would likely not stand given weak case | State: either weight of other evidence or ID reliability undermines prejudice showing | Court: Declined to decide prejudice; held AEDPA review of Strickland not met and remanded (did not resolve underlying prejudice) |
| Proper standard of federal review on summary state-court denials under AEDPA/Harrington | Ninth Circuit applied de novo analysis and rejected state ruling | State/majority: federal courts must identify theories that could have supported state decision and give deference under §2254(d) | Held: Ninth Circuit erred; must consider plausible supporting theories and apply deferential AEDPA review per Harrington |
| Role of suggestiveness vs. reliability in due-process suppression of IDs | Suggestive procedures (same photo twice; prelim hearing issues) made ID unreliable and unconstitutional | Even if suggestive, reliability factors (opportunity to view, attention, certainty, description, time lapse) could sustain ID; suppression not inevitable | Held: Suppression is not automatic; courts must assess reliability under totality of circumstances (Perry/Manson/Biggers); here state court reasonably could find reliability sufficient |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (two‑part ineffective assistance standard: deficient performance and prejudice)
- Harrington v. Richter, 562 U.S. 86 (2011) (federal courts must identify theories that could have supported state court’s summary denial before finding §2254(d) unreasonable)
- Perry v. New Hampshire, 565 U.S. 228 (2012) (due process requires suppression only when procedure was both suggestive and unnecessary; reliability is central)
- Manson v. Braithwaite, 432 U.S. 98 (1977) (reliability factors for eyewitness ID and due‑process framework)
- Neil v. Biggers, 409 U.S. 188 (1972) (factors for assessing reliability of eyewitness identification)
- Simmons v. United States, 390 U.S. 377 (1968) (definition of impermissibly suggestive procedures creating substantial likelihood of misidentification)
- Foster v. California, 394 U.S. 440 (1969) (rare case where pretrial identifications were so suggestive suppression was required)
- Premo v. Moore, 562 U.S. 115 (2011) (deference to state court assessment of Strickland under AEDPA)
- White v. Woodall, 572 U.S. 415 (2014) (recent reiteration of the high bar for overcoming AEDPA deference)
- Renico v. Lett, 559 U.S. 766 (2010) (more general legal rules give state courts greater leeway)
- Knowles v. Mirzayance, 556 U.S. 111 (2009) (Strickland’s general standard affords state courts latitude in applying ineffective‑assistance doctrine)