Plain-English summary
Court: federal habeas relief requires both Brecht actual-prejudice test and AEDPA deference to state-court rulings
The Supreme Court held that when a state court has decided a claim on the merits, federal habeas courts must apply both the Brecht harmless-error (actual prejudice) standard and the deference required by 28 U.S.C. § 2254(d) under the Antiterrorism and Effective Death Penalty Act (AEDPA). The Court reversed the Sixth Circuit and remanded.
Why this matters
This decision clarifies the rules federal courts must follow when reviewing federal constitutional claims raised by state prisoners. It keeps AEDPA's deference to state-court rulings in place while preserving the Brecht harmless-error requirement as an independent barrier to habeas relief. That combination makes it harder for many state prisoners to win federal habeas relief.
Who may feel it
- State prisoners pursuing federal habeas corpus relief
- State courts whose decisions on federal constitutional claims are reviewed
- Federal district and circuit courts that decide habeas petitions
- Defenders, prosecutors, and appellate attorneys handling postconviction cases
Key questions
- How do the Brecht harmless-error standard and AEDPA's § 2254(d) deference interact on federal habeas review?