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Federal Habeas Relief When State Court Determined Error Was Harmless

Case Name: Brown v. Davenport (2022) __ U.S.__ [142 S.Ct. 1510]
Case #: 20-826
Last Updated: April 21, 2022

May a federal habeas court grant relief based solely on its conclusion that the Brecht v. Abrahamson (1993) 507 U.S. 619 test is satisfied, as the Sixth Circuit held, or must the court also find that the state court’s Chapman v. California (1967) 386 U.S. 18 application was unreasonable under 28 U.S.C. § 2254(d)(1), as the Second, Third, Seventh, Ninth, and Tenth Circuits have held?

Held:

After a state court determines that an error at trial did not prejudice a criminal defendant, may a federal court grant habeas relief based solely on its independent assessment of the error’s prejudicial effect under Brecht v. Abrahamson, 507 U. S. 619, 113 S. Ct. 1710, 123 L. Ed. 2d 353 (1993)? Or must a federal court also evaluate the state court’s decision under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA)? The Sixth Circuit ruled that an individual who satisfies Brecht alone is entitled to habeas relief. This was mistaken. When a state court has ruled on the merits of a state prisoner’s claim, a federal court cannot grant relief without first applying both the test this Court outlined in Brecht and the one Congress prescribed in AEDPA.

This case was decided on 4/21/2022.

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