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USA Constitutional Law
Table of Contents: Primary

United States Constitutional Law
United States Supreme
Court Case Summaries
April 18, 2000

United States constitutional Law
United States Supreme Court Case Summaries
April 21, 2000

U.S. Supreme Court Opinions
Case Summaries -April 21, 2000

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CRIMINAL LAW

WILLIAMS v. TAYLOR, WARDEN (4/18/00 - No. 99-6615)
Certiorari to the United States Court of Appeals for the Fourth Circuit
Argued February 28, 2000--Decided April 18, 2000
After petitioner was convicted of two capital murders and other crimes, he
was sentenced to death. The Supreme Court of Virginia affirmed on direct
appeal and later dismissed petitioner's state habeas corpus petition. He
then sought federal habeas relief, requesting, among other things, an
evidentiary hearing on three constitutional claims. Those claims were that
(1) the prosecution had violated Brady v. Maryland, 373 U. S. 83
http://caselaw.findlaw.com/cgi-bin/getcase.pl?navby=case&court=US&vol=373&in
vol=83, in failing to disclose a report of a pretrial psychiatric
examination of Jeffrey Cruse, petitioner's accomplice and the Commonwealth's
main witness against petitioner; (2) the trial was rendered unfair by the
seating of a juror who at voir dire had not revealed possible sources of
bias; and (3) a prosecutor committed misconduct in failing to reveal his
knowledge of the juror's possible bias.
Held: Under §2254(e)(2), as amended by AEDPA, a "fail[ure] to develop" a
claim's factual basis in state court proceedings is not established unless
there is lack of diligence, or some greater fault, attributable to the
prisoner or his counsel. The statute does not bar the evidentiary hearing
petitioner seeks on his juror bias and prosecutorial misconduct claims, but
bars a hearing on his Brady claim because he "failed to develop" that
claim's factual basis in state court and concedes his inability to satisfy
the statute's further stringent conditions for excusing the deficiency. Pp.
6-22.
189 F. 3d 421, affirmed in part, reversed in part, and remanded.
Kennedy, J., delivered the opinion for a unanimous Court.
To read the full text of this opinion, go to:
http://laws.findlaw.com/us/000/99-6615.html

CRIMINAL LAW

WILLIAMS v. TAYLOR, WARDEN (4/18/00 - No. 98-8384)
Certiorari to the United States Court of Appeals for the Fourth Circuit
Argued October 4, 1999--Decided April 18, 2000
A Virginia jury convicted petitioner Williams of robbery and capital murder,
and, after a sentencing hearing, found a probability of future dangerousness
and unanimously fixed his punishment at death. The trial judge imposed the
death sentence, and the Virginia Supreme Court affirmed. In state habeas
corpus proceedings, the same trial judge found that Williams' conviction was
valid, but that his counsel's failure to discover and present significant
mitigating evidence violated his right to the effective assistance of
counsel under Strickland v. Washington, 466 U. S. 668
http://caselaw.findlaw.com/cgi-bin/getcase.pl?navby=case&court=US&vol=466&in
vol=668. In rejecting the trial judge's recommendation that Williams be
resentenced, the State Supreme Court held, inter alia, that the trial judge
had failed to recognize that Strickland had been modified by Lockhart v.
Fretwell, 506 U. S. 364, 369
http://caselaw.findlaw.com/cgi-bin/getcase.pl?navby=case&court=US&vol=506&in
vol=364&pageno=369, and that Williams had not suffered sufficient prejudice
to warrant relief. In habeas corpus proceedings under 28 U. S. C. §2254, the
federal trial judge agreed with the state trial judge that the death
sentence was constitutionally infirm on ineffective-assistance grounds. The
Fourth Circuit reversed, construing §2254(d)(1) to prohibit federal habeas
relief unless the state court had interpreted or applied the relevant
precedent in a manner that reasonable jurists would all agree is
unreasonable. The court declared that it could not say that the Virginia
Supreme Court's decision on prejudice was an unreasonable application of the
Strickland or Lockhart standards established by the Supreme Court.
Held: The judgment is reversed, and the case is remanded.
163 F. 3d 860, reversed and remanded.
Justice Stevens delivered the opinion of the Court as to Parts I, III, and
IV, concluding that Williams was denied his constitutionally guaranteed
right to the effective assistance of counsel, as defined in Strickland, when
his trial lawyers failed to investigate and to present substantial
mitigating evidence to the sentencing jury. Pp. 25-34.
Justice O'Connor delivered the opinion of the Court as to Part II,
concluding that §2254(d)(1) places a new constraint on the power of a
federal habeas court to grant relief to a state prisoner with respect to
claims adjudicated on the merits in state court: The habeas writ may issue
only if the state-court adjudication (1) "was contrary to," or (2) "involved
an unreasonable application of..." clearly established Federal law, as
determined by the Supreme Court of the United States." Pp. 4-15.
To read the full text of this opinion, go to:
http://laws.findlaw.com/us/000/98-8384.html

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April 18, 2000CRIMINAL LAWWILLIAMS v. TAYLOR, WARDEN (4/18/00 - No. 98-8384)
U.S. Supreme Court Opinions Case Summaries - April 18, 2000