Johnson v. Williams

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Habeas Corpus
  • Date Filed: February 20, 2013
  • Case #: 11-465
  • Judge(s)/Court Below: Alito, J., delivered the Court's opinion which Roberts, C.J., and Kennedy, Thomas, Ginsburg, Breyer, Sotomayor, and Kagan, JJ., joined. Scalia, J., filed an opinion concurring in judgment.
  • Full Text Opinion

When a state court addresses some of the claims raised on appeal but does not expressly address a federal claim that is later raised in habeas proceedings, there is a rebuttable presumption that the state court decided the federal claim on its merits.

Respondent was tried and convicted of first degree murder. During jury deliberation, the trial court questioned and dismissed one of the jurors. On appeal, Respondent claimed that this dismissal violated both the Sixth Amendment and California law. The California Court of Appeals held that the juror had been properly dismissed based on California precedent, but did not expressly address the Sixth Amendment claim.

Respondent sought federal habeas relief on the Sixth Amendment claim. The district court denied relief holding that the California Court of Appeals had decided the Sixth Amendment claim on the merits. The Court of Appeals for the Ninth Circuit reversed and held that the California Court of Appeals did not expressly address the Sixth Amendment claim. On de novo review the Ninth Circuit held that the dismissal of the juror violated the Sixth Amendment.

The Supreme Court reversed, holding that when a state court addresses some of the claims raised on appeal but does not expressly address a federal claim that is later raised in habeas proceedings, the federal habeas court must presume that that claim was decided on its merits by the state court. This presumption is subject to rebuttal, but in this case the presumption was not rebutted, and thus under 28 U.S.C. § 2254(d) Respondent is not entitled to federal habeas relief.

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