Shoop v. Hill
139 S. Ct. 504
SCOTUS2019Background
- In 1986 Danny Hill was convicted and sentenced to death in Ohio for the 1985 torture, rape, and murder of 12-year-old Raymond Fife; Ohio courts and this Court initially affirmed convictions and sentence.
- After Atkins v. Virginia (2002) barred execution of the intellectually disabled, Hill raised an Atkins claim in Ohio state courts; the trial court denied relief and the Ohio appellate court affirmed in 2008; Ohio Supreme Court denied review in 2009.
- Hill filed a federal habeas petition under 28 U.S.C. §2254; the District Court denied relief, but the Sixth Circuit reversed and granted habeas under §2254(d)(1), finding Ohio courts unreasonably applied clearly established law.
- The Sixth Circuit’s decision relied heavily on this Court’s subsequent decision in Moore v. Texas, concluding Ohio courts overemphasized Hill’s adaptive strengths and relied on his behavior in prison.
- The State petitioned for certiorari arguing the Sixth Circuit improperly relied on Moore (decided after the state-court rulings) in applying AEDPA’s §2254(d)(1) standard.
- The Supreme Court granted certiorari, vacated the Sixth Circuit’s decision, and remanded because the Sixth Circuit impermissibly relied on Moore rather than only on Supreme Court precedent that was clearly established at the time of the state-court adjudication.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Sixth Circuit permissibly granted habeas relief under 28 U.S.C. §2254(d)(1) based on state courts’ rejection of Hill’s Atkins claim | Hill: Ohio courts unreasonably applied Atkins by overemphasizing adaptive strengths and relying on prison behavior; Moore merely applied Atkins | State: The Sixth Circuit relied on Moore, which postdated the state rulings and thus cannot be "clearly established" Supreme Court law under AEDPA | The Supreme Court vacated the Sixth Circuit decision and remanded, holding the Sixth Circuit improperly relied on Moore and must evaluate the claim using only Supreme Court precedent clearly established at the relevant time |
| Whether Atkins and subsequent precedent provided clearly established rules on assessing adaptive functioning that justified relief | Hill: Atkins (and later Moore) reflect rules forbidding overreliance on adaptive strengths and on prison-developed skills | State: Atkins left implementation to the States and did not clearly establish the specific rules later articulated in Moore | The Court held Atkins did not clearly establish the specific rules the Sixth Circuit applied (Moore-based) and that Moore itself postdated the state rulings, so §2254(d)(1) relief could not be premised on Moore |
| Proper scope of AEDPA deference when later Supreme Court decisions clarify earlier holdings | Hill: Later decisions can illuminate earlier holdings and be treated as applications of existing rules | State: AEDPA requires reliance only on holdings ‘‘clearly established’’ at the time of the state-court decision | The Court emphasized AEDPA’s restriction: federal habeas relief under §2254(d)(1) cannot rest on Supreme Court decisions that postdate the relevant state-court adjudication |
| Whether Hill preserved a §2254(d)(1) claim before the lower courts | Hill: Argued primarily under §2254(d)(2) but later relied on §2254(d)(1) after Moore prompted supplemental briefing | State: The Sixth Circuit adopted a §2254(d)(1) rationale that Hill had not consistently pressed earlier | The Court noted Hill had litigated under §2254(d)(2) and that the Sixth Circuit’s late shift to a Moore-driven §2254(d)(1) analysis compounded the error; vacatur and remand required |
Key Cases Cited
- Atkins v. Virginia, 536 U.S. 304 (2002) (Eighth Amendment bars execution of intellectually disabled defendants)
- Hall v. Florida, 572 U.S. 701 (2014) (IQ cutoff rule unconstitutional; must consider adaptive deficits)
- White v. Woodall, 572 U.S. 415 (2014) (AEDPA limits on federal habeas relief)
- Harrington v. Richter, 562 U.S. 86 (2011) (standard for unreasonable application under AEDPA)
- Hill v. Anderson, 881 F.3d 483 (6th Cir. 2018) (Sixth Circuit granted habeas to Hill relying heavily on Moore)
- Hill v. Ohio, 507 U.S. 1007 (1993) (cert. denied)
- Cain v. Chappell, 870 F.3d 1003 (9th Cir. 2017) (noting Moore could not be clearly established law for earlier state-court decisions)