Woods v. Etherton

It is inappropriate to use the "fairminded jurist" standard when evaluating an appellant's claims for relief on appeal.

After police received an anonymous tip, Appellant was arrested and ultimately convicted of Possession of Cocaine with the Intent to Deliver. At trial, the main controversy centered around whether Appellant was the owner of the cocaine or if it belonged to a co-defendant. After the anonymous tip was recounted twice during trial, Appellant’s counsel objected to it’s admission. The jury was instructed that the tip was not evidence and should only be used for the purposes of determining police actions. As a result, Appellant sought post conviction relief on three grounds: 1) that the admission of the tip violated his Sixth Amendment Confrontation Clause Rights; 2) ineffective assistance of counsel; and 3) an additional ineffective assistance of counsel claim towards his appellate counsel for failing to raise the Confrontation Clause issues. The Court of Appeals for the Sixth Circuit held that Appellant’s counsel was ineffective and found that Appellant’s Confrontation Clause Rights had been violated, however; the court held that it was appropriate to admit the content of the anonymous tip. The United States Supreme Court held that the Sixth Circuit applied an inappropriate standard of review under the Anti-Terrorism and Effective Death Penalty Act of 1996. The court found that the Sixth Circuit improperly used the “fairminded jurist” standard, because this standard does not give enough deference to lower courts and a fairminded jurist could objectively decide otherwise. REVERSED.