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White v. Wheeler No. 14-1372 – Supreme Court [December 14, 2015]

White v. Wheeler

The Supreme Court overrules a Sixth Circuit opinion granting a habeas petition in a death penalty case where a juror was excused over whether they could give sufficient assurance of neutrality or impartiality in considering whether the death penalty should be imposed as an unreasonable application of Witherspoon and Wainwrigth. The Court sets forth a “double deferential” standard of review in Witherspoon-Witt claim as in of ineffective assistance of counsel claims. The court must find that the excusal of the juror for cause was “so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement.” Given the ambiguousness of the juror’s answers, here, the issue should be resolved in favor of the State. The Court stated: “simple disagreement does not overcome the two layers of deference owed by a federal habeas court in this context.” [“As a final matter, this Court again advises the Court of Appeals that the provisions of AEDPA apply with full force even when reviewing a conviction and sentence imposing the death penalty.”]

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