Virginia v. Leblanc

Under 28 U. S. C. §2254(d)(1), the standard for a federal court to review the constitutionality of a state court’s decision vis-a-vis a petition for writ of habeas corpus does not permit the federal court to disturb the state court’s decision unless the state court unreasonably applied federal law and there is “no fairminded disagreement” regarding how it acted unreasonably.

At the age of 16, Respondent was convicted and sentenced to life for rape. After he was sentenced, in Graham v. Florida, 560 U. S. 48 (2010), the U.S. Supreme Court determined that it was a violation of the Sixth Amendment of the U.S. Constitution to sentence juveniles to life terms for non-homicide crimes. Respondent moved to vacate his sentence in Virginia state court pursuant to Graham, and the motion was denied because the state had instituted a “geriatric release program.” The program allowed possible release for Respondent if he displayed sufficient maturity and rehabilitation. Respondent sought relief pursuant to 28 U. S. C. §2254(d)(1), which permits a state convicted defendant to petition to federal courts for a writ of habeas corpus. The federal district court determined that the Virginia court unreasonably applied Graham, and the Fourth Circuit affirmed. The U.S. Supreme Court held that the circumstances presented by the geriatric release program were not clearly established under Graham. Therefore, the state court did not meet the high standard required by §2254(d)(1). The Court noted that the standard for petitioning a state court’s violation to a federal court is that there can be “no fairminded disagreement” regarding the constitutionality of the state court’s decision. The Court determined that the federal district court and the Fourth Circuit were speculating that the geriatric release program conflicted with Graham, because the Court did not yet rule on the geriatric release program in the context of a juvenile life sentence. REVERSED.