No. 25-5286

Samuel Fields v. Laura Plappert, Warden

Lower Court: Sixth Circuit
Docketed: 2025-08-06
Status: Denied
Type: IFP
Amici (1)IFP
Tags: aedpa circuit-court-mandate clearly-established-law exceptional-circumstance habeas-corpus supreme-court-review
Key Terms:
DueProcess HabeasCorpus JusticiabilityDoctri
Latest Conference: 2025-11-07
Question Presented (AI Summary)

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?

Question Presented (OCR Extract)

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 ?

Docket Entries

2025-11-10
Petition DENIED.
2025-10-16
DISTRIBUTED for Conference of 11/7/2025.
2025-10-14
Reply of Samuel Fields submitted.
2025-10-14
Reply of petitioner Samuel Fields filed. (Distributed)
2025-09-29
Brief of Laura Plappert in opposition submitted.
2025-09-29
Brief of respondent Laura Plappert, Warden in opposition filed.
2025-09-05
Amicus brief of National Association of Criminal Defense Lawyers, National Association for Public Defense, Kentucky Association of Criminal Defense Lawyers, and Scholars submitted.
2025-09-05
Brief amici curiae of National Association of Criminal Defense Lawyers, et al. filed.
2025-08-11
Motion to extend the time to file a response is granted and the time is extended to and including October 6, 2025.
2025-08-08
Motion of Laura Plappert for an extension of time submitted.
2025-08-08
Motion to extend the time to file a response from September 5, 2025 to October 6, 2025, submitted to The Clerk.
2025-07-31
Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due September 5, 2025)
2025-06-24
Application (24A1277) granted by Justice Kavanaugh extending the time to file until July 31, 2025.
2025-06-20
Application (24A1277) to extend the time to file a petition for a writ of certiorari from July 1, 2025 to July 31, 2025, submitted to Justice Kavanaugh.

Attorneys

Laura Plappert
Matthew Franklin KuhnOffice of Attorney General of Kentucky, Respondent
Matthew Franklin KuhnOffice of Attorney General of Kentucky, Respondent
National Association of Criminal Defense Lawyers, National Association for Public Defense, Kentucky Association of Criminal Defense Lawyers, and Scholars
Stephen Ross JohnsonRitchie, Johnson & Stovall, P.C., Amicus
Stephen Ross JohnsonRitchie, Johnson & Stovall, P.C., Amicus
Samuel Fields
Daniel Evan KirschFederal Public Defender, Western Dist. of Missouri, Petitioner
Daniel Evan KirschFederal Public Defender, Western Dist. of Missouri, Petitioner