Dennis v. Sec'y, Pa. Dep't of Corr. - 834 F.3d 263 (3d Cir. 2016)

Rule:

A state court decision is an unreasonable application of federal law if the state court identifies the correct governing legal principle, but unreasonably applies that principle to the facts of the prisoner's case. A strong case for habeas relief does not mean the state court's contrary conclusion was unreasonable. Habeas relief may not be granted on the basis that the state court applied clearly established law incorrectly; rather, the inquiry is whether the state court's application of clearly established federal law was objectively unreasonable. A rule's unreasonable application corresponds to the specificity of the rule itself: the more general the rule, the more leeway courts have in reaching outcomes in case-by-case determinations. A state court's determination that a claim lacks merit precludes federal habeas relief so long as fairminded jurists could disagree on the correctness of the state court's decision.

Facts:

Petitioner James Dennis was convicted for the murder of Chedell Williams. For twenty-four years, petitioner unsuccessfully challenged his conviction. The Pennsylvania Supreme Court repeatedly affirmed petitioner’s first-degree murder conviction and sentence and denied his applications for post-conviction relief. Thereafter, petitioner filed an application under 28 U.S.C. § 2254, and the United States District Court for the Eastern District of Pennsylvania granted petitioner the habeas corpus relief, concluding that the Pennsylvania Supreme Court had unreasonably applied Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963), with respect to three pieces of evidence suppressed by the Commonwealth, i.e., a receipt corroborating petitioner’s alibi, an inconsistent statement by the Commonwealth's key eyewitness, and documents indicating that another individual committed the murder. 

Issue:

Under the circumstances, was the petitioner entitled to a grant of habeas relief?

Answer:

Yes.

Conclusion:

The Court affirmed the district court’s grant of habeas relief based on his Brady claims. According to the Court, the Pennsylvania Supreme Court unreasonably applied Brady and its progeny in evaluating the receipt and made unreasonable determinations of fact. Moreover, there was a reasonable probability that, had the police activity sheet been disclosed, the jury would have had a reasonable doubt as to petitioner's guilt. The Pennsylvania Supreme Court's characterization of admissibility as a separate, independent prong of Brady effectively added admissibility as a requirement.