Johnson v. Williams
Annotate this Case
568 U.S. ___ (2013)
A California jury convicted Williams of murder. On direct appeal she claimed that questioning and dismissal of a juror during deliberations violated the Sixth Amendment and California law. Holding that the juror had been properly dismissed for bias, the California Court of Appeal quoted a Supreme Court definition of “impartiality,” but did not expressly acknowledge that it was deciding a Sixth Amendment issue. The state’s highest court remanded in light of its intervening decision that a trial court abused its discretion by dismissing, for failure to deliberate, a juror who appeared to disagree with the rest of the jury. Reaffirming its prior decision, the court of appeal discussed that decision and again failed to expressly acknowledge the federal claim. Williams ought federal habeas relief. The district court applied the deferential standard of review under the Antiterrorism and Effective Death Penalty Act for claims already “adjudicated on the merits in State court,” 28 U. S. C. 2254(d). The Ninth Circuit concluded that the state court had not considered Williams’ Sixth Amendment claim, reviewed that claim de novo, and found violation of the Sixth Amendment. The Supreme Court reversed. When a state court rules against a defendant in an opinion that rejects some of the defendant’s claims but does not expressly address a federal claim, a federal habeas court must presume, subject to rebuttal, that the federal claim was adjudicated on the merits for purposes of AEDPA. Applying that rebuttable presumption, the Ninth Circuit erred. Several facts indicate that the state court did consider the Sixth Amendment claim.
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321 .
SUPREME COURT OF THE UNITED STATES
JOHNSON, ACTING WARDEN v. WILLIAMS
certiorari to the united states court of appeals for the ninth circuit
No. 11–465. Argued October 3, 2012—Decided February 20, 2013
The Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) provides that a federal habeas court may not grant relief to a state prisoner whose claim has already been “adjudicated on the merits in State court,” 28 U. S. C. §2254(d), unless the claim’s adjudication resulted in a decision that was “contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by [this] Court,” §2254(d)(1), or “based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding,” §2254(d)(2).
A California jury convicted respondent Williams of first-degree murder. On direct appeal to the California Court of Appeal, she claimed that the trial court’s questioning and dismissal of a juror during deliberations violated both the Sixth Amendment and California law. In holding that the juror had been properly dismissed for bias, the California Court of Appeal quoted the definition of “impartiality” from United States v. Wood, 299 U. S. 123 –146, but it did not expressly acknowledge that it was deciding a Sixth Amendment issue. The State Supreme Court remanded for further consideration in light of its intervening Cleveland decision, which held that a trial court abused its discretion by dismissing for failure to deliberate a juror who appeared to disagree with the rest of the jury about the evidence. Reaffirming its prior decision on remand, the State Court of Appeal discussed Cleveland, again quoted Wood, and failed to expressly acknowledge that Williams had raised a federal claim.
When Williams later sought federal habeas relief, the District Court applied §2254’s deferential standard of review for claims adjudicated on the merits and denied relief. But the Ninth Circuit concluded that the State Court of Appeal had not considered Williams’ Sixth Amendment claim. The court then reviewed that claim de novo and held that the questioning and dismissal of the juror violated the Sixth Amendment.
1. For purposes of §2254(d), when a state court rules against a defendant in an opinion that rejects some of the defendant’s claims but does not expressly address a federal claim, a federal habeas court must presume, subject to rebuttal, that the federal claim was adjudicated on the merits. Pp. 7–13.
(a) This conclusion follows logically from Harrington v. Richter, 562 U. S. ___. There, the Court held that when a state court issues an order that summarily rejects without discussion all the claims raised by a defendant, including a federal claim that the defendant subsequently presses in federal habeas, the federal habeas court must presume that the federal claim was adjudicated on the merits. Though Richter concerned a state-court order that did not address any of the defendant’s claims, there is no sound reason not to apply its presumption when a state-court opinion addresses some but not all of those claims. Federal habeas courts should not assume that any unaddressed federal claim was simply overlooked because state courts do not uniformly discuss separately every claim referenced by a defendant. In fact, they frequently take a different course. They may view a line of state precedent as fully incorporating a related federal constitutional right, may not regard a fleeting reference to a provision of the Federal Constitution or federal precedent as sufficient to raise a federal claim, or may simply regard a claim as too insubstantial to merit discussion. Pp. 7−10.
(b) Petitioner’s argument for an irrebuttable presumption goes too far. Certainly, if a state standard subsumes the federal standard, the federal claim may be regarded as having been adjudicated on the merits. See Early v. Packer, 537 U. S. 3 . But where, e.g., the state standard is less protective or the federal precedent was mentioned in passing, the presumption may be rebutted—either by a habeas petitioner (to show that the federal court should consider the claim de novo) or by the State (to show that the federal claim should be regarded as procedurally defaulted). See Coleman v. Thompson, 501 U. S. 722 . An irrebuttable presumption that state courts never overlook federal claims would sometimes be wrong. It would also improperly excise §2254(d)’s on-the-merits requirement, for a claim that is rejected as a result of sheer inadvertence has not been evaluated on the merits. The experience of the lower federal courts shows that allowing federal habeas petitioners to rebut the presumption will not prompt an unduly burdensome flood of litigation. Pp. 10−13.
2. Applying the rebuttable presumption of merits adjudication here, the Ninth Circuit erred by finding that the State Court of Appeal overlooked Williams’ Sixth Amendment claim. Several facts lead to that conclusion. Most important is that the court discussed Cleveland, a State Supreme Court case that in turn examined three Federal Court of Appeals cases concerning the Sixth Amendment implications of discharging holdout jurors. Though Cleveland refused to follow those cases, the views of the federal courts of appeals do not bind a State Supreme Court when it decides a federal constitutional question. Regardless of whether a California court would consider Williams’ state-law and Sixth Amendment claims to be coextensive, their similarity makes it unlikely that the State Court of Appeal decided one while overlooking the other. The State Court of Appeal’s quotation of Wood, supra, at 145−146, further confirms that it was well aware that the juror’s questioning and dismissal implicated federal law. Williams’ litigation strategy also supports this result. She treated her state and federal claims as interchangeable, so it is not surprising that the state courts did as well. Notably, Williams neither petitioned the State Court of Appeal for rehearing nor argued in subsequent state and federal proceedings that the state court had failed to adjudicate her Sixth Amendment claim on the merits. Pp. 13−16.
646 F. 3d 626, reversed and remanded.
Alito, J., delivered the opinion of the Court, in which Roberts, C. J., and Kennedy, Thomas, Ginsburg, Breyer, Sotomayor, and Kagan, JJ., joined. Scalia, J., filed an opinion concurring in the judgment.