Brown v. Davenport
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Brown v. Davenport and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Brown v. Davenport.
The Supreme Court addressed the interaction between the Brecht and AEDPA standards in federal habeas corpus cases. The Court found that the Sixth Circuit erred by granting habeas relief to Ervine Davenport without applying both standards. The decision clarified that satisfying Brecht is necessary but not sufficient for habeas relief under AEDPA.
Holding
The single most important “bottom line” of what the Court decided in Brown v. Davenport.
The Court held that a federal court cannot grant habeas relief without applying both the Brecht and AEDPA standards.
Constitutional Concepts
These are the Constitution-related themes that appear in Brown v. Davenport. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Brown v. Davenport
The case involves the application of procedural due process in the context of shackling a defendant during trial without a special need, as governed by the Fourteenth Amendment.
Syllabus excerpt (verbatim)Deck v. Missouri, 544 U. S. 622, in which this Court held that the Fourteenth Amendment's Due Process Clause generally forbids shackling a criminal defendant at trial absent 'a special need.'
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Why Remedies and Relief is relevant to Brown v. Davenport
The case addresses the limits on federal habeas relief under AEDPA, which is a form of judicial remedy.
Syllabus excerpt (verbatim)Congress instructed that a federal court 'shall not. . . gran[t]' relief with respect to a claim that has been adjudicated on the merits in state court 'unless' certain conditions are met. § 2254(d).
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Why Judicial Review is relevant to Brown v. Davenport
The case involves the power of federal courts to review state court decisions under AEDPA and Brecht standards.
Syllabus excerpt (verbatim)This Court granted certiorari to resolve a circuit conflict about the proper interaction between the tests found in Brecht and AEDPA.
Key Quotes
Short excerpts from the syllabus in Brown v. Davenport that support the summary and concepts above.
When a state court has ruled on the merits of a state prisoner's claim, a federal court cannot grant habeas relief without applying both the test this Court outlined in Brecht and the one Congress prescribed in AEDPA.
The Sixth Circuit erred in granting habeas relief to Mr. Davenport based solely on its assessment that he could satisfy the Brecht standard.
Proof of prejudice under Brecht does not equate to a successful showing under AEDPA.
