Samuel Fields v. Laura Plappert, Warden
DueProcess HabeasCorpus JusticiabilityDoctri
May a subsequent decision of this Court calling into question the correctness and integrity of a circuit court's judgment qualify as an exceptional circumstance justifying a recall of the circuit court's mandate, and if so, did the lower court err in denying the motion to recall?
This Court has recognized that “ [i]n the constitutional sense, trial by jury in a criminal case necessarily implies at the very least that the ‘evidence developed’ against a defendant shall come from the witness stand in a public courtroom where there is full judicial protection of the defendant’s right of confrontation, of cross examination, and of counsel.” Turner v. Louisiana , 379 U.S. 466, 47273 (1965) . In Sam Fields ’s federal habeas case, a panel of the Sixth Circuit found (in unison with the Sixth Ci rcuit’s prior decisions) that this Court’s general rule, as stated in Turner and other cases of this Court , qualified as clearly established federal law under 28 U.S.C. § 2254(d)(1) (“AEDPA”) . Accordingly , Fields was entitled to a determination of whether the state court’s decision in his case —regarding the jury ’s consideration of physical evidence that did not come from the courtroom —was an unreasonabl e application of this general rule . But d uring en banc review, a majority determined that this Court “abrogated” th e prior Sixth Circuit decisions by subsequently interpreting § 2254(d)(1) to exclude general or abstract rules from qualifying as clearly established Supreme Court law. The majority further concluded that the rule was not a holding of Turner or any other Supreme Court case for the purposes of AEDPA . As a result , Fields no longer was entitled to a determination of whether the statecourt decision unreasonably applied this Court ’s rule. This Court subsequently issued Andrew v. White , 145 S. Ct. 75 , 78 (2025) , in which this Court ruled that a similar circuit court decision finding that the general or abstract rule at issue there could not satisfy AEDPA’s “clearly established law” requirement was “wrong.” The Court ruled that § 2254(d)(1) does not exclude abstract or general principles from qualifying as clearly established law , and when this Court relies on a legal rule or principle to decide a case, that principle is a holding of this Cour t for purposes of AEDPA. This Court remanded the case to the circuit court for a determination of whether the state -court decision unreasonably applied this Court’s general rule . Less than 30 days after this Court decided Andrew , Fields requested the Sixth Circuit to recall its mandat e on the ground that Andrew created an exceptional circumstance warranting the recall . In a divided decision, the Sixth Circuit denied the motion. This case thus presents the following question s: May a subsequent decision of this Court calling into question the correctness and integrity of a circuit court’s judgment qualify as an exceptional circumstance justifying a recall of the circuit court’s mandate , and if so, did the lower court err in denying the motion to recall ?