White v. Woodall

PETITIONER: Randy White, Warden
RESPONDENT: Robert Keith Woodall
LOCATION: Caldwell County Circuit Court

DOCKET NO.: 12-794
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT:

CITATION: 572 US 1701 (2014)
ARGUED: Dec 11, 2013
GRANTED: Jun 27, 2013
DECIDED: Apr 23, 2014

ADVOCATES:
Laurence E. Komp - for the respondent (appointed by the Court)
Susan R. Lenz - for the petitioner

Facts of the case

On January 25, 1997, a sixteen-year-old girl was kidnapped, murdered, and raped. After an investigation, the police arrested Robert Woodall, who subsequently pled guilty to capital murder, capital kidnapping, and first-degree rape. At trial, Woodall invoked his Fifth Amendment right to avoid self-incrimination and declined to testify, and so he asked the judge to instruct the jury not to make any adverse inferences from that decision. The judge refused to issue the "no adverse inference" instruction and stated that, by entering a guilty plea, Woodall waived his right to be free from self-incrimination. The jury found Woodall guilty on all charges and the judge sentenced him to the death penalty and two subsequent life sentences.

Woodall appealed to the Kentucky Supreme Court, which affirmed both Woodall's conviction and sentence. In 2006, Woodall filed a habeus corpus petition in federal court, and that court held that the trial court violated Woodall's Fifth Amendment right when it refused to offer the requested jury instruction. In addition, that court also held that Woodall's Fifth, Eighth, and Fourteenth Amendment rights were violated when the trial court allowed the state to dismiss an African-American juror without a mandatory hearing for cause. On appeal, the U.S. Court of Appeals for the Sixth Circuit affirmed the district court's decision on the issue of self-incrimination but did not address the other issues.

Question

(1) Did the trial court violate Woodall's Fifth Amendment rights when it refused to provide a "no adverse inference" instruction to the jury in a capital punishment case in which the defendant has pled guilty?

(2) Was the trial court's failure to provide a "no adverse inference" instruction a harmless error in light of the overwhelming evidence of guilt that resulted in a guilty plea?

Media for White v. Woodall

Audio Transcription for Oral Argument - December 11, 2013 in White v. Woodall

Audio Transcription for Opinion Announcement - April 23, 2014 in White v. Woodall

Justice Scalia has our opinion this morning in case 12-794, White versus Woodall.

This case is here on writ of certiorari to the United States Court of Appeals for the Sixth Circuit.

It involves the intersection of the Antiterrorism and Effective Death Penalty Act, so called AEDPA and the privilege against self-incrimination protected by the Fifth Amendment.

In 1998, the respondent, Robert Woodall pleaded guilty to capital murder, capital kidnapping, and first degree rape.

He did not testify during the sentencing phase of his trial and his attorney asked the trial judge to instruct the jury that it could not draw an adverse inference of any kind from his silence.

The judge declined to give that instruction.

The -- the Kentucky Supreme Court affirmed the denial and we denied respondent's petition for certiorari on direct appeal.

In 2006, this crime happened in 1998.

In 2006, respondent filed this petition for a writ of habeas corpus in Federal District Court.

The petition argues that our decisions in Carter versus Kentucky, Estelle versus Smith, and Mitchell versus United States, collectively established that criminal defendants are entitled to a no adverse inference instruction at sentencing.According to the petition, the Kentucky Supreme Court unreasonably applied those cases by failing to uphold respondent's right to such an instruction.

The District Judge granted the writ.

The Sixth Circuit affirmed.

It ordered Kentucky to re -- resentence respondent within 180 days or release him.

We reverse the judgment of the Sixth Circuit.

To obtain relief under AEDPA, a prisoner must show that the adjudication of his claim in state court “Resulted in a decision that was contrary to or involved an unreasonable application of clearly established Federal law as determined by the Supreme Court of the United States.”

The Sixth Circuit based its ruling on the unreasonable application prong of this standard, which as we have reminded the Sixth Circuit many times, is extremely difficult to meet.

A state court's ruling satisfies the unreasonable application prong only if the error -- if the error alleged is so obvious that there could be no fair-minded disagreement about its existence.

Respondent's Fifth Amendment claim fails because there are reasonable justifications for the Kentucky Supreme Court's ruling.

Carter, the first case respondent cites held that a no adverse inference instruction is required during the guilt phase of a criminal trial.

This was the -- the sentencing phase.

Estelle, the second case, concerned the prosecution's use of an involuntary psychiatric examination during a sentencing hearing.

And the third case, Mitchell, disapproved a trial judge's drawing on an adverse inference from the defendant's silence at sentencing but with respect to “The factual circumstances and details of the crime.”

Those holdings do not clearly establish the broad sentencing phase rule respondent asserts here, nor was the Kentucky Supreme Court's ruling on unreasonable application of the rules that were clearly established by those holdings, although Estelle held that the Fifth Amendment applies to the penalty phase, it did not address the scope of the privilege in that context.

And in Mitchell, we -- we expressly reserve judgment on whether a sentencing judge may rely on a defendant's silence to draw adverse inferences regarding the defendant's lack of remorse and acceptance of responsibility.

That reservation alone dooms respondent's habeas claim.

It suggest that defendants are not entitled to an -- an across the board instruction like the one at issue here which would have prohibited any adverse inference based on respondent's silence.

The Sixth Circuit sidestep these fatal defects by invoking the apocryphal notion that habeas relief is warranted whenever a state court unreasonably refuses to extend a holding of this Court to a new context in which the holding “should apply.”

We have never adopted that interpretation of AEDPA's unreasonable-application clause and we reject it today.

AEDPA provides a remedy for instances in which a state court unreasonably applies this Court's precedent.

It does not require state courts to extend that precedent or license federal courts to treat the failure to do so as an error.