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Chappell v. Ayala

Issues

Does a state court’s determination that a trial court committed a harmless error amount to an “adjudication on the merits,” as defined in 28 U.S.C. § 2254(d), thereby limiting a federal court’s ability to review the trial court’s conviction only when the standards stated in the aforementioned provision are met?

Court below

United States Court of Appeals for the Ninth Circuit

The Supreme Court will determine to what extent federal courts can evaluate state court determinations of federal error regarding a federal question. Kevin Chappell, Warden of the State of California, contends that federal courts must grant significant deference to state court determinations denying federal habeas relief for convicted defendants based on a finding that any error that occurred during a trial was a harmless error. Hector Ayala, a prisoner, counters that federal courts should have the opportunity to independently review federal habeas petitions for error and determine how much prejudice the defendant suffered when state courts determined an error was harmless. The Supreme Court’s decision will impact the level of deference afforded to state courts in determinations of harmless error and will affect the jury selection process.

Questions as Framed for the Court by the Parties

Was a state court's rejection of a claim of federal constitutional error on the ground that any error, if one occurred, was harmless beyond a reasonable doubt an “adjudicat[ion] on the merits” within the meaning of 28 U.S.C. § 2254(d), so that a federal court may set aside the resulting final state conviction only if the defendant can satisfy the restrictive standards imposed by that provision?; and
Did the court of appeals properly applied [sic] the standard articulated in Brecht v. Abrahamson?

In 1985, Hector Ayala was charged with “three counts of murder, one count of attempted murder, one count of robbery and three counts of attempted robbery.” See Ayala v. Wong, 756 F.3d 656, 660. In 1989, jury selection began with the review of over 200 juror questionnaires followed by juror interviews by the court and parties.

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Cone v. Bell

Issues

Whether the procedural bar prevents federal habeas courts from reviewing habeas petitions that state courts dismissed based on state procedural rules against re-litigating fully adjudicated claims, and whether federal courts can review state application of such rules.

Court below

United States Court of Appeals for the Sixth Circuit

Gary Cone was convicted and sentenced to death in the Criminal Court of Shelby County, Tennessee, for the murder of two people. Subsequent to Cone’s direct appeal, the state made available documents that both supported Cone’s defense that he was a drug addict at the time of the killings and impeached the testimonies of several witnesses. Respondent Bell argues for the state that Cone is procedurally barred from raising his grounds for relief in a federal habeas corpus review, as state courts already rejected it and Cone failed to properly argue it in the state courts. Petitioner Cone, however, argues that there should not be a procedural bar in this case because he did not receive the new information until his second request for post-conviction review, so the courts erroneously found that his claim had been previously decided. He also argues that it is the federal court’s duty in federal habeas review to examine grounds for relief based on federal law. The Supreme Court’s decision in this case could implicate the methods by which individuals convicted in state court can litigate their claims, both in state courts and upon federal habeas corpus review. Additionally, the Court’s decision could clarify the roles of state and federal courts in an area of law with implications for the federalist structure.

Questions as Framed for the Court by the Parties

The question presented is whether petitioner is entitled to federal habeas review of his claim that the State suppressed material evidence in violation of Brady v. Maryland, which encompasses two sub-questions:
1. Is a federal habeas claim “procedurally defaulted” because it has been presented twice to the state courts?
2. Is a federal habeas court powerless to recognize that a state court erred in holding that state law precludes reviewing a claim?

In 1982, Gary Bradford Cone, a Vietnam veteran, was found guilty and sentenced to death in a Tennessee criminal court for the murder of two elderly people during the commission of a robbery. See Cone v. Bell, 492 F.3d 743, 748 (6th Cir.