Woods v. Etherton

PETITIONER: Jeffrey Woods
RESPONDENT: Timothy Etherton
LOCATION: Ionia County, Michigan

DOCKET NO.: 15-723
DECIDED BY: Roberts Court (2016- )
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 578 US (2016)
GRANTED: Apr 04, 2016
DECIDED: Apr 04, 2016

Facts of the case

In 2006, Michigan law enforcement received an anonymous tip that two white males were traveling between Detroit and Grand Rapids on I-96 in an Audi and were possibly carrying cocaine. Timothy Etherton was driving a car that matched that description, and he was pulled over. Both he and his passenger, Ryan Pollie, were arrested when the officers found 125.2 grams of cocaine in the car. During Etherton’s trial in state court, Pollie testified that he accompanied Etherton to Detroit without knowing that they were traveling there to obtain cocaine and that Etherton did not inform Pollie about the drugs until the two started back to Grand Rapids. Several police officers also testified at trial and described the anonymous tip, which was “not evidence” but admitted “only to show why the police did what they did.” Etherton was convicted of possession of cocaine with intent to deliver. The Michigan Court of Appeals affirmed his conviction, and the Michigan Supreme Court denied leave to appeal.

Etherton sought state postconviction relief and argued that the admission of the anonymous tip violated his rights under the Confrontation Clause of the Sixth Amendment, his trial counsel was ineffective for failing to object to the tip on that ground, and his counsel on direct appeal was ineffective for failing to raise the previous two claims. The state court denied postconviction relief because Etherton failed to prove that his counsel acted unreasonably. Etherton then sought federal habeas relief under the Antiterrorism and Effective Death Penalty Act (AEDPA), which specifies that federal habeas relief is only available after a state court’s denial if the state court’s decision involved an unreasonable application of clearly established federal law. If “fairminded jurists” could disagree as to the validity of the state court’s determination, federal habeas relief is unavailable. The district court denied relief by finding the state court’s denial of relief was objectively reasonable because Etherton’s counsel was adequately prepared for trial. The U.S. Court of Appeals for the Sixth Circuit reversed and held that Etherton’s right to confrontation had been violated because the anonymous tip was referenced four times during the trial, which indicated that the tip was admitted for its truth. The court concluded Etherton’s counsel had been constitutionally ineffective and “no fairminded jurist could conclude otherwise.”

Question

Did the U.S. Court of Appeals for the Sixth Circuit properly apply the standard from the Antiterrorism and Effective Death Penalty Act (AEDPA) that, as long as “fairminded jurists” could disagree about the state court’s conclusion, a federal court should not overrule a state court’s denial of habeas relief?

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