Holland v. Jackson

PETITIONER: Flora Holland, Warden
RESPONDENT: Jessie L. Jackson
LOCATION: University Court Housing Project

DOCKET NO.: 03-1200
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 542 US 649 (2004)
DECIDED: Jun 28, 2004
GRANTED: Jun 28, 2004

Facts of the case

Jessie L. Jackson was sentenced to life in prison in Tennessee in 1987 for the murder of James Crawley. Jackson sought post-conviction relief on the grounds that his trial counsel was ineffective and had failed to conduct an adequate investigation. In order to establish ineffective assistance of counsel as a violation of the Sixth Amendment based on the Supreme Court’s decision in Strickland v. Washington, the accused must show a lack of reasonably effective counsel and that there was a reasonable probability that, but for counsel’s unprofessional errors, the result at trial would have been different. The state court denied relief and determined that Jackson’s counsel was not deficient and that, regardless, he had not suffered prejudice as a result of his counsel’s performance.

Jackson then sought federal habeas relief, and the district court confirmed the state court’s denial of relief. Despite finding that there had been ineffective assistance of counsel and a reasonable likelihood of prejudice, the district court held that a federal court can only grant relief if the state court’s determination was contrary to established federal law, which was not the case here. The U.S. Court of Appeals for the Sixth Circuit reversed and held that Jackson was entitled to relief because the state court unreasonably applied the Strickland test and the state court’s opinion was contrary to the established Strickland precedent in that it applied a preponderance-of-the-evidence standard rather than a reasonable-probability standard.

Question

Did the federal appellate court properly determine that the state court unreasonably applied the test from Strickland v. Washington?