Parker v. Matthews

The Court of Appeals for the Sixth Circuit improperly set aside a murder conviction in a clear example of "using federal habeas corpus review as a vehicle to second-guess the reasonable decisions of state courts" as proscribed by the Antiterrorism and Effective Death Penalty Act (AEDPA).

Respondent borrowed money and used it to purchase a gun. The next night he broke into his estranged wife’s home and murdered both her and her mother. At trial attempted to get his charged reduced to manslaughter by arguing that he was operating under extreme emotional distress. The jury convicted Respondent on all charges and sentenced him to death. The Kentucky Supreme Court affirmed holding that Respondent's evidence was insufficient to show extreme emotional distress, and rejected Respondent’s claim of prosecutorial misconduct without discussion.

Respondent filed a habeas petition claiming that the Kentucky Supreme Court had rejected clearly established federal law both in deciding that he had not acted under extreme emotional distress and in rejecting the prosecutorial misconduct claim. The District Court dismissed the petition but the Court of Appeals for the Sixth Circuit reversed. It held that the Kentucky Supreme Court had improperly placed the burden of proving extreme emotional distress on Respondent and that certain remarks by the prosecutor denied the respondent due process.

The Supreme Court reversed. It held that the Sixth Circuit ignored the role of the jury and instead substituted its own opinion. The jury instructions placed the burden of proof on the State, and the jury determined that the State met that burden. Additionally, the Supreme Court held that the Sixth Circuit erred by consulting its own precedent rather than Supreme Court precedent, an error it had also made two sessions prior.