White v. Woodall
134 S. Ct. 1697
| SCOTUS | 2014Background
- Respondent Robert Woodall pleaded guilty to capital murder, kidnapping, and first-degree rape after overwhelming forensic evidence and admissions; the convictions included the statutory aggravating circumstance.
- At the penalty phase Woodall did not testify; defense requested a jury instruction that no adverse inference be drawn from his silence; the trial court denied the instruction.
- The Kentucky Supreme Court affirmed, distinguishing the guilt-phase rule requiring a no-adverse-inference instruction (Carter) and concluding those precedents did not compel the instruction at penalty.
- Woodall filed federal habeas relief; the District Court granted relief on Fifth Amendment grounds and the Sixth Circuit affirmed, ordering resentencing or release.
- The U.S. Supreme Court granted certiorari and reversed the Sixth Circuit, holding the Kentucky Supreme Court’s rejection was not an objectively unreasonable application of this Court’s precedents under 28 U.S.C. §2254(d)(1).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether refusal to give a penalty-phase no-adverse-inference instruction violated the Fifth Amendment under AEDPA deference | Woodall: Carter and Estelle together require the instruction at penalty; state court unreasonably refused to extend the rule | Warden/Kentucky: Carter applies to guilt phase; Mitchell and other precedents allow room for penalty-phase differences; state decision reasonable | Court: Kentucky’s decision not objectively unreasonable under §2254(d)(1); habeas relief improperly granted |
| Whether Carter’s guilt-phase rule extends categorically to penalty-phase instructions | Woodall: Carter + Estelle mean no basis to distinguish guilt vs penalty; instruction required | Kentucky: Carter is limited to guilt phase; Estelle/ Mitchell do not mandate a blanket penalty-phase instruction | Court: Not settled law; reasonable minds could disagree; no clearly established rule requiring blanket penalty instruction |
| Whether Mitchell forbids any penalty-phase inference from silence (including remorse) | Woodall: Mitchell supports broad protection at sentencing | Kentucky: Mitchell was narrowly about factual determinations of the crime and left open sentencing inferences; remorse may be considered | Court: Mitchell leaves room for fairminded disagreement; it does not compel the requested blanket instruction |
| Whether federal habeas courts may set aside state-court rulings for failing to "extend" Supreme Court precedent to new contexts under §2254(d)(1) | Woodall: State unreasonably refused to extend governing principle to penalty context | Warden: §2254(d)(1) permits relief only when state unreasonably applies clearly established holdings; failure to extend is not per se AEDPA error | Court: Declines to adopt "unreasonable-refusal-to-extend" as independent basis; relief available only where no fairminded disagreement about applicable Supreme Court holdings |
Key Cases Cited
- Carter v. Kentucky, 450 U.S. 288 (requiring no-adverse-inference instruction at guilt phase upon request)
- Estelle v. Smith, 451 U.S. 454 (Fifth Amendment protections apply at penalty phase; compelled psychiatric testimony violated privilege)
- Mitchell v. United States, 526 U.S. 314 (prohibited adverse inference at sentencing on facts of the crime; reserved other sentencing issues)
- Williams v. Taylor, 529 U.S. 362 (AEDPA §2254(d)(1) analysis; state court unreasonably applying Supreme Court precedent standard)
- Lockyer v. Andrade, 538 U.S. 63 (clarifies "objectively unreasonable" standard under AEDPA)
- Harrington v. Richter, 562 U.S. 86 (state-court decision must be so lacking in justification that no fairminded disagreement is possible under AEDPA)