(decided January 21, 2025)
The Antiterrorism and Effective Death Penalty Act (“AEDPA”), at 28 U.S.C. § 2254(d)(1), prohibits federal courts from overruling a criminal judgment of a state court unless the judgment was “contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States . . ..” (emphasis added). In this case, the Court sent a state court murder conviction back to the lower federal Court of Appeals that first reviewed it for a violation of a “Federal law” for further consideration of AEDPA’s “Federal law” limitation.
In the underlying state court murder trial, the defendant, Brenda Andrew, had been accused of deliberately setting a fatal trap for her husband where she and her frequent “date” could make it appear that the murder was committed by unknown assailants. At her trial, the prosecution introduced substantial, relevant evidence that supported its deliberate trap charges, which Ms. Andrew denied. However, the prosecution also introduced irrelevant, and therefore inadmissible evidence of sexual misconduct by Ms. Andrew, that Ms. Andrew claimed to have violated her federal right to “due process of law.” See Amendment XIV, § 1, U.S. Const. The jury did not believe Ms. Andrew’s version of the fatal attack on her husband, found her guilty of his murder, and sentenced her to death.
In Ms. Andrew’s federal habeas corpus case, a federal Court of Appeals ruled that her federal case was barred by AEDPA, because, as the Court of Appeals believed, no Supreme Court precedent had been identified that made the introduction of irrelevant, but prejudicial proof against a criminal defendant a violation of “Federal law.” The Supreme Court disagreed, and cited its 1991 precedent of Payne v. Tennessee, 501 U.S. 808 (1991) as the required authority.
COMMENMT: The Payne case has significant factual distinctions from Ms. Andrew’s case, making it doubtful, and less than “clear,” that that case interpreted “due process of law” to require exclusion, or at least correction, of “unduly” prejudicial evidence against a criminal defendant in her criminal trial. However, other Supreme Court caselaw that is more on point factually does say so. The Court’s 7-2 majority correctly remanded this case to the federal Court of Appeals to reconsider the AEDPA prohibition under Section 2254(d)(1) in its entirety.
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