Brown v. Davenport

Brown v. Davenport

Opinion

Justice Gorsuch delivered the opinion of the Court.

After a state court determines that an error at trial did not prejudice a criminal [*8]  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.

One evening in 2007, Annette White attended a gathering with Ervine Davenport. On the drive home, Mr. Davenport killed Ms. White. At trial, the only questions concerned why and how. Mr. Davenport claimed self-defense and testified to that effect. On his account, Ms. White grew angry during the trip and tried to grab the steering wheel from him while he was driving. Then she pulled out a box cutter and cut his arm. Mr. Davenport responded by extending one arm and pinning Ms. White against the passenger side of the car, with his hand under her chin. Eventually, she stopped struggling. On discovering that Ms. White was no longer breathing, Mr. Davenport [*9]  panicked and left her body in a field.

The prosecution offered a very different version of events. It stressed that Ms. White was 5’2” tall, 103 pounds, and had a broken wrist, while Mr. Davenport was 6’5” tall and weighed nearly 300 pounds. The prosecution presented evidence that Mr. Davenport had bragged to others before the killing that, if he had a problem with someone, he would choke the person. Days before Ms. White’s death, Mr. Davenport had done just that—strangling another woman until she lost consciousness and urinated on herself. Nor, on the prosecution’s account, were Mr. Davenport’s actions after Ms. White’s death consistent with his claim of self-defense. Instead of contacting the police, he not only abandoned his victim’s body. He also fled the scene and later visited Ms. White’s home where he stole electronics and food. He told a witness, too, that he “had to off ” Ms. White.

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