Supreme Court says Payne v. Tennessee provides clearly established due-process rule for AEDPA claims in 7-2 per curiam decision
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The Supreme Court, in a 7–2 per curiam opinion, held that the due-process rule stated in Payne v. Tennessee is a "clearly established" rule of federal law for purposes of 28 U.S.C. § 2254(d), allowing federal habeas petitioners to press claims that overly prejudicial evidence rendered their trials fundamentally unfair.
The decision is significant for postconviction litigation because AEDPA limits federal habeas relief to state-court decisions that are contrary to, or an unreasonable application of, clearly established federal law as determined by prior Supreme Court holdings. The Court concluded that Payne supplies a sufficient rule that prisoners may invoke under AEDPA, and it clarified when the "fair-minded jurist" test applies in the AEDPA framework.
The case involved Brenda Andrew, who was convicted and sentenced to death after a prosecution that introduced extensive evidence about her sexual history and other personal conduct; the prosecution conceded some of that material was irrelevant. The Tenth Circuit denied habeas relief, concluding the evidence was harmless because the proof of guilt was overwhelming and because Payne did not supply a clearly established rule. The Supreme Court reversed, finding that Payne's statement that evidence so unduly prejudicial as to render a trial fundamentally unfair is a liberty-protecting rule that AEDPA recognizes as "clearly established."
Panelists on the Federal Judicial Center podcast emphasized both the immediate procedural effect and the doctrinal clarification. Evan Lee said the ruling clarified "the way they determined that it was clearly established, and then also a clarification of when the fair minded jurist test applies and to what it applies within the AEDPA regime." Laurie Levinson characterized the ruling as a major development for postconviction relief: "This case is enormous in the area of postconviction relief because when the Supreme Court says that now you can use Payne v. Tennessee to claim that prejudicial evidence is a due process violation... that means under laws like AEDPA, this type of claim can now be brought."
The Court also addressed the interplay between dicta and holdings in identifying "clearly established" federal law, reiterating that AEDPA looks to prior Supreme Court holdings, not mere dicta. The dissent argued that the majority failed to apply the fair-minded jurist standard correctly; the majority responded that that standard applies only after a rule has been identified as clearly established.
Lower courts will likely see a new wave of AEDPA claims invoking Payne to attack trials where the admission of highly prejudicial evidence was central to the defense's arguments. The case was remanded for further proceedings consistent with the Supreme Court's ruling.
The decision is significant for postconviction litigation because AEDPA limits federal habeas relief to state-court decisions that are contrary to, or an unreasonable application of, clearly established federal law as determined by prior Supreme Court holdings. The Court concluded that Payne supplies a sufficient rule that prisoners may invoke under AEDPA, and it clarified when the "fair-minded jurist" test applies in the AEDPA framework.
The case involved Brenda Andrew, who was convicted and sentenced to death after a prosecution that introduced extensive evidence about her sexual history and other personal conduct; the prosecution conceded some of that material was irrelevant. The Tenth Circuit denied habeas relief, concluding the evidence was harmless because the proof of guilt was overwhelming and because Payne did not supply a clearly established rule. The Supreme Court reversed, finding that Payne's statement that evidence so unduly prejudicial as to render a trial fundamentally unfair is a liberty-protecting rule that AEDPA recognizes as "clearly established."
Panelists on the Federal Judicial Center podcast emphasized both the immediate procedural effect and the doctrinal clarification. Evan Lee said the ruling clarified "the way they determined that it was clearly established, and then also a clarification of when the fair minded jurist test applies and to what it applies within the AEDPA regime." Laurie Levinson characterized the ruling as a major development for postconviction relief: "This case is enormous in the area of postconviction relief because when the Supreme Court says that now you can use Payne v. Tennessee to claim that prejudicial evidence is a due process violation... that means under laws like AEDPA, this type of claim can now be brought."
The Court also addressed the interplay between dicta and holdings in identifying "clearly established" federal law, reiterating that AEDPA looks to prior Supreme Court holdings, not mere dicta. The dissent argued that the majority failed to apply the fair-minded jurist standard correctly; the majority responded that that standard applies only after a rule has been identified as clearly established.
Lower courts will likely see a new wave of AEDPA claims invoking Payne to attack trials where the admission of highly prejudicial evidence was central to the defense's arguments. The case was remanded for further proceedings consistent with the Supreme Court's ruling.
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