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Brown v. Davenport

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Supreme Court of the United States
Brown v. Davenport
Term: 2021
Important Dates
Argued: October 5, 2021
Decided: April 21, 2022
Outcome
reversed
Vote
6-3
Majority
Neil Gorsuch • Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Brett Kavanaugh • Amy Coney Barrett
Dissenting
Elena Kagan • Stephen Breyer • Sonia Sotomayor

Brown v. Davenport is a case that was decided by the Supreme Court of the United States on April 21, 2022, during the court's October 2021-2022 term. The case was argued before the Court on October 5, 2021.[1]

The court reversed the decision of the United States Court of Appeals for the 6th Circuit in a 6-3 ruling, holding that the 6th Circuit erred when it granted Ervine Davenport’s habeas corpus petition based solely on the test SCOTUS established in Brecht v. Abrahamson (1993). Justice Neil Gorsuch delivered the majority opinion of the court. Justice Elena Kagan filed a dissenting opinion, joined by Justices Stephen Breyer and Sonia Sotomayor.[2] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: In 2008, a jury convicted Ervine Davenport of first-degree murder. Davenport was visibly shackled at his feet, waist, and hands throughout the trial, and based on this he appealed. After the state appellate courts ultimately upheld his conviction, Davenport filed a petition for a federal writ of habeas corpus. Using the test established by the U.S. Supreme Court in Brecht v. Abrahamson (1993), the United States Court of Appeals for the 6th Circuit granted Davenport a conditional writ of habeas corpus, holding that the prosecution did not show beyond a reasonable doubt that the shackling error did not have a “substantial and injurious effect or influence in determining the jury's verdict." The 6th Circuit used the Brecht test exclusively in its habeas determination.[3] Click here to learn more about the case's background.
  • The issue: The case concerned the standard necessary to grant federal habeas relief to a person held in state custody.
  • The question presented: "May a federal habeas court grant relief based solely on its conclusion that the Brecht (1993) test is satisfied, as the Sixth Circuit held, or must the court also find that the state court’s Chapman (1967) application was unreasonable under § 2254(d)(1), as the Second, Third, Seventh, Ninth, and Tenth Circuits have held?"[4]
  • The outcome: The court reversed the 6th Circuit's decision in a 6-3 ruling, holding that the 6th Circuit erred when it granted Ervine Davenport’s habeas corpus petition based solely on the test SCOTUS established in Brecht v. Abrahamson (1993).[2]


    • The case came on a writ of certiorari to the United States Court of Appeals for the 6th Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    Background

    In 2008, Ervine Davenport was convicted of first-degree murder following a jury trial in a Michigan state court. During the trial, he was visibly shackled at his feet, waist, and one wrist. He appealed his conviction in state court on a number of grounds, including that he was denied due process by being required to wear shackles at his trial. The Michigan Court of Appeals denied Davenport relief, but the Michigan Supreme Court reversed the appellate court and remanded the case to the trial court for further action. It directed the trial court to determine if the jurors saw Davenport's shackles, and, if they did, require the prosecutor to show beyond a reasonable doubt that the shackles did not contribute to Davenport's conviction. At a 2011 evidentiary hearing in which all 12 former jurors testified, several jurors said they saw the shackles but that it didn't affect their deliberations or verdict. Based largely on this testimony, the trial court found that the prosecution proved beyond a reasonable doubt the shackling error did not affect the verdict and was harmless. On appeal, the Michigan Court of Appeals affirmed the trial court's finding and upheld Davenport's conviction. The Michigan Supreme Court denied further appeal.[3]

    After exhausting all appeals at the state level, Davenport challenged his conviction in a federal habeas corpus petition filed pursuant to 28 U.S.C. § 2254 on a single ground: being shackled at trial. While the State of Michigan recognized that Davenport's shackling was unconstitutional, it argued that the error was harmless. The United States District Court for the Western District of Michigan agreed with the state and denied Davenport's petition. Davenport subsequently appealed to the United States Court of Appeals for the 6th Circuit.[3]

    In reviewing Davenport's habeas petition, a three-judge panel of the 6th Circuit applied the standard set out by the U.S. Supreme Court in Brecht v. Abrahamson (1993) that habeas relief must be granted where an error "had substantial and injurious effect or influence in determining the jury's verdict." Given that the Supreme Court found shackling to be "inherently prejudicial" in Deck v. Missouri (2005) and the state did not present overwhelming evidence to support a conviction for first-degree murder, the 6th Circuit held that the state did not meet its burden to show shackling Davenport did not have a "substantial and injurious effect or influence in determining the jury's verdict."[3] The court specifically noted that there was no reason to analyze whether the prosecution had proved beyond a reasonable doubt that the shackling error was harmless, a standard set out for direct appeals by the Supreme Court in Chapman v. California (1967), because the Chapman standard was subsumed within the more stringent Brecht standard.[3]

    By a 2-1 vote, the 6th Circuit reversed the district court's holding, granted Davenport a conditional writ of habeas corpus, and remanded the case for further proceedings. Mike Brown, as the acting warden of the prison where Davenport is being held, petitioned for an en banc review by the entire 16-judge 6th Circuit. Being denied that, he appealed to the U.S. Supreme Court.[3]

    Question presented

    The petitioner presented the following question to the court:[4]

    Question presented:
    “ May a federal habeas court grant relief based solely on its conclusion that the Brecht test is satisfied, as the Sixth Circuit held, or must the court also find that the state court’s Chapman application was unreasonable under § 2254(d)(1), as the Second, Third, Seventh, Ninth, and Tenth Circuits have held?[5] ”

    Oral argument

    Audio

    Audio of oral argument:[6]



    Transcript

    Transcript of oral argument:[7]

    Outcome

    In a 6-3 opinion, the court reversed the 6th Circuit's judgment, holding that the 6th Circuit erred when it granted Ervine Davenport’s habeas corpus petition based solely on the test SCOTUS established in Brecht v. Abrahamson (1993). Justice Neil Gorsuch delivered the majority opinion of the court. Justice Elena Kagan filed a dissenting opinion, joined by Justices Stephen Breyer and Sonia Sotomayor.[2]

    Opinion

    In the court's majority opinion, Justice Neil Gorsuch wrote:[2]

    “

    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 (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.
    ...
    When Congress supplies a constitutionally valid rule of decision, federal courts must follow it. In AEDPA, Congress announced such a rule. It instructed that a federal court “shall not . . . gran[t]” relief with respect to a claim that has been adjudicated on the merits in state court "unless" the state court’s decision was (1) “contrary to” or an “unreasonable application of ” clearly established federal law, as determined by the decisions of this Court, or (2) based on an “unreasonable determination of the facts” presented in the state-court proceeding. § 2254(d) (emphasis added).

    The upshot of these directions for our case is straightforward. No one questions that a state court’s harmless-error determination qualifies as an adjudication on the merits under AEDPA. See Davis v. Ayala, 576 U. S. 257, 269 (2015); Fry v. Pliler, 551 U. S. 112, 119 (2007); Early v. Packer, 537 U. S. 3, 10–11 (2002) (per curiam). No one disputes that such a decision exists here. Nor does Mr. Davenport pursue any claim to relief under § 2254(d)(2). From this, it follows that he must satisfy § 2254(d)(1) to secure federal habeas relief. To be sure, where Brecht is implicated a federal court must also ensure a habeas petitioner has carried his burden under its terms before granting relief. But in cases like ours satisfying Brecht is only a necessary, not a sufficient, condition to relief. AEDPA too must be satisfied. The Sixth Circuit erred in holding otherwise. [5]

    		”
    —Justice Neil Gorsuch

    Dissenting opinion

    Justice Elena Kagan filed a dissenting opinion, joined by Justices Stephen Breyer and Sonia Sotomayor.

    In her dissent, Justice Kagan wrote:[2]

    “

    Twice in recent years, this Court has addressed how a federal habeas court is to evaluate whether a state trial error was harmless. See Fry v. Pliler, 551 U. S. 112, 119–120 (2007); Davis v. Ayala, 576 U. S. 257, 267–270 (2015). And twice, we have made clear that the habeas court need apply only the standard prescribed in Brecht v. Abrahamson, 507 U. S. 619 (1993); it need not also run through the test set out in the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). That is because, we have both times explained, the Brecht standard “obviously subsumes” the “more liberal” AEDPA one: If a defendant meets the former, he will “necessarily” meet the latter too. Fry, 551 U. S., at 120; Ayala, 576 U. S., at 270.

    Today, the Court discards those crystal-clear statements, subscribed to on each occasion by every Justice. The majority reverses the Court of Appeals for following our prior guidance, allowing the use of the Brecht test alone. And in declaring Brecht insufficient, the majority consigns future habeas courts to a regimen of make-work. Now those courts will have to jump through AEDPA’s hoops as well, even though that extra analysis will never lead to a different result. I respectfully dissent from that pointless demand. [5]

    		”
    —Justice Elena Kagan

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[8]

    The court agreed to hear 68 cases during its 2021-2022 term.[9] Four cases were dismissed and one case was removed from the argument calendar.[10]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ Note: The case came to the court of appeals as Davenport v. MacLaren. MacLaren was the warden of the prison where Davenport was held at the time of that appeal; Mike Brown was the acting warden when the case was appealed to the U.S. Supreme Court.
    2. ↑ 2.0 2.1 2.2 2.3 2.4 Supreme Court of the United States, Brown v. Davenport, decided April 21, 2022
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 United States Court of Appeals for the 6th Circuit, Davenport v. MacLaren, decided June 30, 2020
    4. ↑ 4.0 4.1 Supreme Court of the United States, "Petition for writ of certiorari in Brown v. Davenport," December 14, 2020
    5. ↑ 5.0 5.1 5.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed October 5, 2021
    7. ↑ Supreme Court of the United States, "Brown v. Davenport - oral argument transcript," accessed October 5, 2021
    8. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    9. ↑ Consolidated cases are counted as one case for purposes of this number.
    10. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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