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2022 Supreme(US)(scotus) 639

SUPREME COURT OF THE UNITED STATES
Neil Gorsuch
Brown – Appellant
Versus
Davenport – Respondent



Syllabus

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.

SUPREME COURT OF THE UNITED STATES

Syllabus

BROWN, ACTING WARDEN v. DAVENPORT CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

No. 20–826. Argued October 5, 2021—Decided April 21, 2022 Ervine Davenport was convicted of first-degree murder following a jury trial where, at times, he sat shackled at a table with a “privacy screen.” On appeal, he argued that his conviction should be set aside in light of Deck v. Missouri, 544 U. S. 622, in which this Court held that the Four- teenth Amendment’s Due Process Clause generally forbids shackling a criminal defendant at trial absent “a special need.” Id., at 626. Find- ing no “special need” articulated in the record, the Michigan Supreme Court agreed that a Deck violation had occurred and remanded the case to the trial court to determine under Chapman v. California, 386 U. S. 18, whether the prosecution could establish that the Deck error was harmless beyond a reasonable doubt. On remand, the trial court conducted an evidentiary hearing at which jurors testified that the shackles had not affected their verdict and concluded that the State had carried its burden. Mr. Davenport appealed again, and the Mich- igan Court of Appeals affirmed the trial court. The Michigan Supreme Court declined review. Mr. Davenport petitioned for federal habeas relief. The District Court found relief unwarranted under the Antiterrorism and Effective Death Penalty Act of 1996, which limits the power of federal courts to issue habeas relief to state prisoners. See 28 U. S. C. §2254(d). A di- vided Sixth Circuit panel reversed, declining to analyze the case under AEDPA. Instead, the court held that its review was governed only by Brecht v. Abrahamson, 507 U. S. 619, which held that a state prisoner seeking to challenge his conviction on the basis of a state court’s Chap- man error must show that the error had a “ ‘substantial and injurious effect or influence’ ” on the trial’s outcome, id., at 637. Persuaded that Mr. Davenport could satisfy Brecht, the Sixth Circuit granted federal 2 BROWN v. DAVENPORT

Syllabus

habeas relief and ordered Michigan either to retry or release Mr. Dav- enport. This Court granted certiorari to resolve a circuit conflict about the proper interaction between the tests found in Brecht and AEDPA. Held: When a state court has ruled on the merits of a state prisoner’s claim, a federal court cannot grant habeas relief without applying both the test this Court outlined in Brecht and the one Congress prescribed in AEDPA; the Sixth Circuit erred in granting habeas relief to Mr. Davenport based solely on its assessment that he could satisfy the Brecht standard. Pp. 6–25. (a) When Congress supplies a constitutionally valid rule of decision, federal courts must follow it. In AEDPA, Congress 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” certain con- ditions are met. §2254(d). To be sure, the court below in this case was required to ensure that petitioner carried his burden under the terms of Brecht. But satisfying Brecht is only a necessary condition to habeas relief here; AEDPA must also be satisfied. The Sixth Circuit erred in holding otherwise. Pp. 6–7. (b) Since the founding, Congress has authorized federal

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