Williams v. Taylor

PETITIONER: Williams
RESPONDENT: Taylor
LOCATION: Massachusetts Office for Administration and Finance

DOCKET NO.: 99-6615
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Fourth Circuit

CITATION: 529 US 420 (2000)
ARGUED: Feb 28, 2000
DECIDED: Apr 18, 2000

ADVOCATES:
Donald R. Curry - Richmond, Virginia, argued the cause for the respondent
John H. Blume - Argued the cause for the petitioner

Facts of the case

Michael Wayne Williams was sentenced to death after he was convicted of two capital murders. Ultimately, Williams sought federal habeas relief, in which he requested an evidentiary hearing on three constitutional claims, regarding the fairness of his trial, which he had tried unsuccessfully to develop in the state-court proceedings. The District Court granted Williams' evidentiary hearing. However, before any hearing could be held, the Court of Appeals granted the Commonwealth's requests for an emergency stay and for a writ of mandamus and prohibition. The Commonwealth argued that Williams' evidentiary hearing was prohibited by federal law as amended by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). On remand, the District Court dismissed Williams' petition citing the AEDPA statute and finding that Williams failed to show "actual innocence." In affirming, the Court of Appeals found that Williams could not satisfy the statute's conditions for excusing his failure to develop the facts of his claims and barred him from receiving an evidentiary hearing.

Question

Does federal law, as amended by the Antiterrorism and Effective Death Penalty Act of 1996, bar an evidentiary hearing, if the petitioner has failed to develop the factual basis of his claims in State court proceedings despite diligent efforts?

Media for Williams v. Taylor

Audio Transcription for Oral Argument - February 28, 2000 in Williams v. Taylor

Audio Transcription for Opinion Announcement - April 18, 2000 in Williams v. Taylor

William H. Rehnquist:

Opinions in two cases named Williams against Taylor are going to be announced today, the first one will be announced by Justice Kennedy.

Anthony M. Kennedy:

The Williams versus Taylor opinion that I am going to announce is 99-6615.

The similarity in the names presents a coincidence that will do nothing but confuse.

In this Williams versus Taylor, 99-6615, a Virginia jury convicted the petitioner Michael Wayne Williams of two capital murders, Williams received a death sentence.

He later sought a writ of habeas corpus in Federal Court and requested an evidentiary hearing on certain constitutional claims.

The Court of Appeals for the Fourth Circuit, in agreement with the United States District Court, ruled that the petitioner was not entitled to a hearing on these claims in his federal habeas action.

The petitioner’s execution was about to go forward and we issued a stay order on the evening of the punishment being carried out.

We then granted certiorari to determine the correct statutory interpretation of the federal statute which controls the question of whether or not the petitioner may receive the hearing on his claims.

The provision at issue is consist of one sentence in the Antiterrorism and Effective Death Penalty Act of 1996.

The sentece is the first sentence in 28 U.S.C. 2254(e)(2).

In effect, the sentence says that an evidentiary hearing, as a general rule, is not permitted in a federal habeas action, if the habeas applicant has failed to develop the factual basis of the claim in State Court, and the relevant phrase that we must concentrate upon is "has failed to develop the factual basis".

In this case, the petitioner attempted to present to the United States District Court three claims that had not been a subject of the State Court evidentiary hearing.

The Commonwealth of Virginia urges that whatever the reason for not developing the claims in the State Court, the fact is, there was no such development.

In this sense, the Commonwealth argues the petitioner has failed to develop a factual basis for its constitutional arguments and as a consequence, the statute (according to the Commonwealth) bars an evidentiary hearing in Federal Court.

This is a no fault interpretation of the statute, we do not agree with it.

We conclude that Congress used the word “fail” in the sense of saying that a person has not taken the necessary steps to develop his claims by reason of some omission or fault or negligence on his part.

This is the sense we hold in which Congress has used the phrase “failed to develop the factual basis of the claim”.

Now, the Court of Appeals for the Fourth Circuit in this case, like every other Court of Appeals which has interpreted the statute, agreed with this interpretation.

In our view, the Court of Appeals was not entirely correct however in how it applied the standard.

We do agree with the Court of Appeals that the petitioner did not exercise the necessary diligence with reference to a claim regarding the prosecution’s alleged non-disclosure of his accomplice’s psychiatric report.

As to petitioner's two other claims which involved allegations of juror bias and prosecutorial misconduct however.

We disagree with the Court of Appeals application of the diligence standard.

We hold that petitioner was diligent in his efforts to develop the facts underlying these two claims.

The statute therefore erects no bar to an evidentiary hearing on these matters in United States District Court.

We remand the case for further proceedings and the opinion is unanimous.