Brown v. Davenport

Summary

The Supreme Court held that when a state court has adjudicated a state prisoner's claim on the merits, a federal habeas court must apply both Brecht's actual-prejudice test and AEDPA's 28 U.S.C. § 2254(d) standard before granting relief; satisfying Brecht is a necessary but not sufficient condition. Applying AEDPA to Ervine Davenport's Deck shackling claim, the Court concluded the Michigan Court of Appeals' Chapman harmless-beyond-a-reasonable-doubt determination was neither contrary to nor an unreasonable application of Holbrook v. Flynn or Chapman, so Davenport could not obtain relief even assuming Brecht prejudice. The Court rejected the argument that Fry v. Pliler and Davis v. Ayala made a separate AEDPA inquiry unnecessary, stressing that the two tests pose different questions and draw on different bodies of law. Justice Kagan, joined by Justices Breyer and Sotomayor, dissented, arguing that Fry and Ayala unanimously established that Brecht subsumes AEDPA and that the majority's dual-test regimen is pointless make-work.