Mays v. Hines

Under 28 U.S.C §2254(d)(2), a writ of habeas corpus shall not be granted with respect to any claim that was adjudicated on the merits in State court proceedings unless adjudication resulted in a decision that was based on an unreasonable determination of the facts in light of the evidenced presented in the State court proceedings.

A jury found Respondent guilty of murder. In a post-conviction trial, more information regarding another witness was revealed. The Sixth Circuit granted Respondent’s Writ of Habeas Corpus, despite overwhelming evidence of his guilt, because his attorney was aware at the time of the original trial that the witness could have been used as an alternative suspect but decided to spare the witness of the embarrassment. The Supreme Court held that this information would not have changed the outcome of the trial and that the Sixth Circuit violated Congress’ prohibition on disturbing state-court judgments on federal habeas review absent an error that lies “‘beyond any possibility for fair-minded disagreement.’” Shinn v. Kayer, 592 U.S. ___, ___ (2020) (per curium) (slip op., at 1); 28 U.S.C. §2254(d). The Supreme Court found evidence against Respondent to overwhelmingly indicate his guilt. By comparison, the testimony of the witness who found the body did not change the outcome. An attempt to show them as another possible suspect would not have mattered because the jury had ample evidence to find Respondent guilty. The witness’s testimony also did not indicate that Respondent was the culprit. REVERSED.