Law School Case Brief
Williams v. Taylor (2000) , Terry Williams v. John Taylor - 529 U.S. 362, 120 S. Ct. 1495 (2000)
Whether or not a federal court can issue a writ of habeas corpus under the "unreasonable application" clause, the statute is clear that habeas may issue under 28 U.S.C.S. § 2254(d)(1) if a state court "decision" is contrary to clearly established federal law.
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. Concluding that such punishment was "proper" and "just," the trial judge imposed the death sentence. The Virginia Supreme Court affirmed. In state habeas corpus proceedings, the same trial judge found, on the evidence adduced after hearings, 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, 80 L. Ed. 2d 674, 104 S. Ct. 2052. 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, 122 L. Ed. 2d 180, 113 S. Ct. 838, 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 federal judge identified five categories of mitigating evidence that counsel had failed to introduce and rejected the argument that such failure had been a strategic decision to rely primarily on the fact that Williams had confessed voluntarily. As to prejudice, the judge determined, among other things, that there was a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different. Applying an amended version of § 2254(d)(1) enacted in the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), the judge concluded that the Virginia Supreme Court's decision "was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States." 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.
Did the state supreme court decision refusing to set aside Williams’ death sentence involve an unreasonable application of, clearly established federal law within the meaning of 28 U.S.C.S. § 2254(d)(1)?
The Court reversed the judgment of the federal appellate court, which determined that Williams’ death sentence was not constitutionally infirm. The Court determined that Williams’ constitutional right to the effective assistance of counsel was violated and that the state supreme court's decision refusing to set aside Williams’ death sentence was contrary to, or involved an unreasonable application of, clearly established federal law within the meaning of 28 U.S.C.S. § 2254(d)(1).
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