No. 20-1084

Jefferson S. Dunn, Commissioner, Alabama Department of Corrections v. Matthew Reeves

Lower Court: Eleventh Circuit
Docketed: 2021-02-09
Status: Judgment Issued
Type: Paid
Amici (1)Relisted (8) Experienced Counsel
Tags: aedpa aedpa-standard comity federal-review federalism habeas-corpus habeas-review ineffective-assistance ineffective-assistance-of-counsel state-court-deference strickland-standard strickland-v-washington
Key Terms:
HabeasCorpus
Latest Conference: 2021-07-01 (distributed 8 times)
Question Presented (AI Summary)

Whether the Eleventh Circuit violated § 2254(d) by readily attributing error to the state court

Question Presented (from Petition)

QUESTION PRESENTED Federal courts reviewing a state court decision under 28 U.S.C. § 2254(d) must not be “read[y] to attribute error” to a state court for at least two reasons. Woodford v. Visciotti, 537 U.S. 19, 24 (2002). First, federal courts are to “presum[e] that state courts know and follow the law.” Jd. And, second, such skeptical review is “incompatible with § 2254(d)’s highly deferential standard for evaluating state-court rulings, which demands that state-court decisions be given the benefit of the doubt.” Id. (cleaned up). The state court here provided several pages of analysis regarding the applicable standard for assessing Matthew Reeves’s ineffective assistance of counsel claim, and the court’s opinion included numerous quotes from and citations to precedents from the Eleventh Circuit and this Court. The state court ultimately concluded that, “[ijn this case, Reeves’s failure to call his attorneys to testify is fatal to his claims of ineffective assistance of counsel.” Pet.App.272a (emphasis added). The Eleventh Circuit read the state court to have held that, “in every case,” failure to call counsel to testify is fatal to an ineffective assistance of counsel claim. And because the state court had purportedly created and used this per se rule that unreasonably applied Strickland v. Washington, 466 U.S. 668 (1984), the Eleventh Circuit was “unconstrained by § 2254’s deference” and was free to assess Reeves’s claim de novo. Pet.App.3la. The court then granted habeas relief. The question presented is whether the Eleventh Circuit violated § 2254(d) by readily attributing error to the state court. i STATEMENT OF

Docket Entries

2021-08-03
JUDGMENT ISSUED.
2021-07-02
Petition GRANTED. Judgment REVERSED and case REMANDED for proceedings consistent with the <a href = 'https://www.supremecourt.gov/opinions/20pdf/20-1084_19m1.pdf'>opinion</a> of the Court. Justice Breyer dissents. <a href = 'https://www.supremecourt.gov/opinions/20pdf/20-1084_19m1.pdf'>Opinion</a> per curiam. (Detached <a href = 'https://www.supremecourt.gov/opinions/20pdf/20-1084_19m1.pdf'>Opinion</a>) Justice Sotomayor, with whom Justice Kagan joins, dissenting. (Detached <a href = 'https://www.supremecourt.gov/opinions/20pdf/20-1084_19m1.pdf'>Opinion</a>)
2021-07-01
DISTRIBUTED for Conference of 7/1/2021.
2021-06-21
DISTRIBUTED for Conference of 6/24/2021.
2021-06-14
DISTRIBUTED for Conference of 6/17/2021.
2021-06-07
DISTRIBUTED for Conference of 6/10/2021.
2021-06-01
DISTRIBUTED for Conference of 6/3/2021.
2021-05-24
DISTRIBUTED for Conference of 5/27/2021.
2021-05-04
DISTRIBUTED for Conference of 5/20/2021.
2021-05-03
Record received from the U.S.C.A. 11th Circuit. The record is electronic.
2021-04-30
Record Requested.
2021-04-27
Reply of petitioner Commissioner, Alabama Dept. of Corrections filed. (Distributed)
2021-04-27
DISTRIBUTED for Conference of 5/13/2021.
2021-04-12
Brief of respondent Matthew Reeves in opposition filed.
2021-03-11
Brief amici curiae of State of Arizona, et al. filed.
2021-02-18
Motion to extend the time to file a response is granted and the time is extended to and including April 12, 2021.
2021-02-17
Motion to extend the time to file a response from March 11, 2021 to April 12, 2021, submitted to The Clerk.
2021-02-05
Petition for a writ of certiorari filed. (Response due March 11, 2021)

Attorneys

Commissioner, Alabama Dept. of Corrections
Edmund Gerard LaCour Jr.Office of the Attorney General, Petitioner
Edmund Gerard LaCour Jr.Office of the Attorney General, Petitioner
Matthew Reeves
Robert N. HochmanSidley Austin, LLP, Respondent
Robert N. HochmanSidley Austin, LLP, Respondent
State of Arizona
Lacey Stover GardOffice of the Attorney General, Amicus
Lacey Stover GardOffice of the Attorney General, Amicus