Supreme Court rules on 'clearly established' federal habeas law

[JURIST] The US Supreme Court [official website] ruled [opinion, PDF] Wednesday in White v. Woodall [SCOTUSblog backgrounder] that because the Supreme Court of Kentucky's [official website] rejection of Robert Keith Woodall's Fifth Amendment [text] claim was not objectively unreasonable, the US Court of Appeals for the Sixth Circuit [official website] erred in granting the writ of habeas corpus. The case arose after Woodall pleaded guilty to capital murder, capital kidnapping and first-degree rape. During the penalty trial, Woodall requested that the judge provide jury instructions that they should not draw inferences from his decision not to testify at trial. The judge refused the instruction, determining that Woodall had waived his right not to self-incriminate when he pleaded guilty. Woodall was convicted, and his conviction was affirmed by the Supreme Court of Kentucky. He then filed a habeas petition. The US District Court for the Western District of Kentucky [official website] found that the refusal of jury instructions violated Woodall's Fifth Amendment right, and the Sixth Circuit affirmed [opinion, text]. The Court, in a 6-3 vote, ruled that because the drawing of an adverse inference from defendant's silence is only disallowed at the guilt stage of a trial, the court did not need to decide whether a no-adverse-inference instruction was required in the specific circumstances of Woodall's case. Thus, the Supreme Court of Kentucky's ruling was not contrary to clearly established law and was, therefore, not unreasonable.

The Supreme Court has heard a variety of criminal procedure cases recently. Last month the court granted certiorari [JURIST report] in a dispute concerning the proper procedures a criminal defendant must adhere to in a federal habeas corpus petition. In February the court ruled [JURIST report] 6-3 in Kaley v. United States that a criminal defendant who has been indicted is not constitutionally entitled to contest a grand jury's finding of probable cause underlying a pre-trial seizure of assets. In December the court ruled [JURIST] in Kansas v. Cheever that the Fifth Amendment does not prohibit the government from introducing evidence from a court-ordered mental evaluation of a criminal defendant to rebut that defendant's presentation of expert testimony in support of a defense of voluntary intoxication. In November the court heard oral arguments [JURIST report] in Fernandez v. California, considering whether the Fourth Amendment [text] allows police to search an individual's home based solely on a co-tenant's consent after the police arrested the objecting individual and removed him from the scene.

 

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