Woods v. Donald
135 S. Ct. 1372
| SCOTUS | 2015

Background

  • Donald was charged with felony murder and armed robbery in Michigan based on his participation in a plan to rob a drug dealer; codefendants Liggins and Zaya pleaded guilty.
  • At trial, the prosecution sought to admit a chart of phone calls among defendants; Donald's counsel declined to object, stating he had no dog in the race.
  • During testimony about the chart, Donald’s counsel was briefly absent from the courtroom; the judge proceeded after a short recess.
  • Donald was convicted on all counts and received a life sentence for felony murder plus concurrent armed-robbery terms; he appealed alleging ineffective assistance of counsel due to the absence.
  • The Michigan Court of Appeals rejected the claim; the federal district court granted habeas relief and the Sixth Circuit affirmed, applying Cronic to presump­tive prejudice.
  • The Supreme Court granted certiorari and reversed, holding that Cronic does not apply to the circumstances presented and that AEDPA review requires deference.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Does Cronic apply to counsel absence during codefendants' testimony? Donald: absence was a critical stage and per se prejudice should apply. Respondent: no existing decision clearly extends Cronic to this form of testimony. Not applicable; per se prejudice not established.
Was the state court's decision an unreasonable application of federal law under AEDPA? Donald: state court misapplied Cronic and imposed per se prejudice. Woods: AEDPA requires deferential review of state-court rulings. No; decision not contrary to or an unreasonable application of clearly established law.

Key Cases Cited

  • United States v. Cronic, 466 U.S. 648 (U.S. 1984) (presumption of prejudice when defendant is denied counsel at a critical trial stage)
  • Bell v. Cone, 535 U.S. 685 (U.S. 2002) (defines critical stage; significant consequences to the accused)
  • Harrington v. Richter, 562 U.S. 86 (U.S. 2011) (doubly deferential AEDPA review; standard for unreasonable application)
  • Cullen v. Pinholster, 563 U.S. 170 (U.S. 2011) (clarifies clearly established law encompasses holdings, not dicta)
  • Carey v. Musladin, 549 U.S. 70 (U.S. 2006) (limits on prejudice based on courtroom conduct and symbolism)
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