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Name: Parker v. Matthews
Case #: 11-845
Court: US Supreme Court
District USSup
Opinion Date: 06/11/2012
Subsequent History: 132 S.Ct. 2148; 183 L.Ed.2d 32

The deferential review under AEDPA does not allow for second-guessing reasonable decisions of state courts. The Sixth Circuit issued a writ of habeas corpus in a capital case from Kentucky on two grounds. The U.S. Supreme Court held that neither was valid. First, the Sixth Circuit held that the Kentucky Supreme Court improperly rejected the petitioner’s sufficiency-of-the-evidence claim. The Kentucky court rejected the claim on two grounds. The Sixth Circuit held that one of the grounds violated of the due process clause because it involved a retroactive application of an “unexpected and indefensible” judicial revision of the Kentucky murder statute. However, because one ground was sufficient to reject the claim, it was irrelevant that the state court also invoked a ground of questionable validity. As to the state court’s conclusion that evidence supported a finding of no extreme emotional disturbance, the U.S. Supreme Court held that the standard of Jackson v. Virginia (1979) 443 U.S. 307, 319, had not been applied in an unreasonable manner. The Sixth Circuit overstepped the proper limits of its authority when it resolved a factual conflict in favor of an expert’s testimony. Second, the Sixth Circuit’s holding that remarks made the prosecutor during closing argument violated due process was reversed. Because the standard in Darden v. Wainwright (1986) 477 U. S. 168, is very general and leaves courts more leeway in reaching outcomes in case-by-case determinations, the Sixth Circuit should not have set aside the state court’s decision. The Sixth Circuit also erred by following its own pre-AEDPA authority.