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Name: Sexton v. Beaudreaux
Case #: 17-1106
Court: US Supreme Court
District USSup
Opinion Date: 06/28/2018
Subsequent History: 138 S.Ct. 2555

Federal habeas relief reversed where Ninth Circuit did not properly apply the AEDPA standard for evaluating state court judgments with no reasoned decision on the merits. Beaudreaux was found guilty of first degree murder and robbery in California State court. His conviction was affirmed on direct appeal and his state habeas petitions were summarily denied. He filed a federal habeas petition, which the district court denied. The Ninth Circuit reversed. The court mainly conducted a de novo analysis of the merits of a would-be motion to suppress pretrial identification evidence, based in part on arguments and theories that Beaudreaux had not presented to the state court. The Ninth determined that trial counsel’s failure to file the suppression motion prejudiced Beaudreaux. The court then concluded that the state court’s denial of the claim was objectively unreasonable under AEDPA. The state petitioned for certiorari. Held: Reversed in per curiam opinion. In federal habeas cases, when there is no reasoned state-court decision on the merits, the federal court “must determine what arguments or theories . . . could have supported the state court’s decision; and then it must ask whether it is possible fairminded jurists could disagree that those arguments or theories are inconsistent with the holding in a prior decision of” the U.S. Supreme Court. (Harrington v. Richter (2011) 562 U. S. 86, 102.) The court here concluded that the Ninth Circuit did not properly apply this standard. In this case, there was no reasoned state court decision. However, the state court could have reasonably concluded that counsel’s performance was not deficient because counsel could have reasonably determined that the motion to suppress would fail. (See Premo v. Moore (2011) 562 U. S. 115, 124.) Additionally, the state court could have reasonably concluded that that the suppression motion would have failed because Beaudreaux failed to prove that, under the totality of the circumstances, the identification was not reliable. (See Neil v. Biggers (1972) 409 U.S. 188.)

The full opinion is available on the court’s website here: