Williams v. Johnson

The appropriate standard of review when a state court overlooks a federal claim is the standard set forth in 28 § U.S.C. 2254(d).

Petitioner was convicted of first-degree murder by a California jury. Petitioner appealed to the California Court of Appeals claiming that a juror was improperly dismissed in violation of the Sixth Amendment of the United States Constitution. The California Court of Appeals held that the dismissal was proper, but did not address Petitioner's Sixth Amendment claim. Petitioner appealed to The State Supreme Court, which remanded and held that the juror dismissal was improper, but again did not address Petitioner's Sixth Amendment claim. On remand, the California Court of Appeals affirmed their prior decision, but again did not address Petitioner's Sixth Amendment claim. Petitioner then sought federal habeas relief. The Court of Appeals for the Ninth Circuit held that the state courts had not addressed Petitioner's Sixth Amendment claim, reviewed the claim de novo, and determined that the juror dismissal violated the Sixth Amendment. Petitioner appealed, and the United States Supreme Court granted certiorari in forma papirus to determine the appropriate standard of review when a state court overlooks a federal claim.