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Name: Carey v. Musladin
Case #: 05-785
Court: US Supreme Court
District USSup
Opinion Date: 12/11/2006
Subsequent History: 127 S.Ct 649; 166 L.Ed.2d 482

In this case, the Supreme Court found that under the requirement of AEDPA, there was no “clearly established Federal law, as determined by the Supreme Court of the United States,” considering whether a defendant’s right to a fair trial was impacted by spectators displaying buttons at the jury trial. At appellant’s murder trial, members of the victim’s family, seated in the front row, wore buttons depicting the victim’s image. The trial court declined to grant the request of the defense to prohibit the practice, stating that it saw no possible prejudice. The Ninth Circuit granted habeas relief, applying the holdings of Estelle v. Williams, 425 U.S. 501 (1976) and Holbrook v. Flynn, 475 U.S. 560 (1986) which considered the effect of courtroom practices on defendants’ fair-trial rights. (Williams dealt with requiring the defendant to stand trial in prison clothes and Flynn permitted the positioning of uniformed state troopers directly behind the defendant.) But the Supreme Court here disagreed, finding that Wiliams and Flynn considered state-sponsored practices as compared to the type of spectator conduct in this case. Because there is a lack of holdings regarding the type of spectator conduct evidenced in this case, the Court concluded that the state courts did not “unreasonably apply clearly established Federal law,” and ordered the Ninth Circuit Court of Appeals judgment vacated.