''Brown v. Davenport'', 596 U.S. 118 (2022), was a case decided by the
United States Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
. The case concerned whether
habeas relief
''Habeas corpus'' (; from Medieval Latin, ) is a recourse in law through which a person can report an unlawful detention or imprisonment to a court and request that the court order the custodian of the person, usually a prison official, t ...
may be granted if the ''Brecht v. Abrahamson'' test alone is satisfied, or if the application of ''
Chapman v. California
''Chapman v. California'', 386 U.S. 18 (1967),''Chapman v. California'', 386 United States Reports, U.S.]18(1967) was a decision by the Supreme Court of the United States that a federal Harmless error, "harmless error" rule must apply, instead of ...
'' by the state courts was unreasonable because of the Antiterrorism and Effective Death Penalty Act of 1996, AEDPA. The court held that federal courts can not grant habeas relief when state courts have already ruled on a prisoner's claim, unless the situation satisfies the test laid out in ''Brecht v. Abrahamson'', and the test laid out in AEDPA.
Background
In 2008, Ervine Davenport was convicted of
first-degree murder
Murder is the unlawful killing of another human without justification or valid excuse, especially the unlawful killing of another human with malice aforethought. ("The killing of another person without justification or excuse, especially the c ...
. His conviction was challenged because during his trial he had been placed in shackles. His wrists, waist, and ankles were all restrained, but there was a curtain to prevent the jury from seeing the shackles. The state said that although the shackles were unconstitutional, they did not effect the jury's verdict. Michigan's Court of Appeals agreed with the state. The Michigan Supreme Court disagreed, however, after several jurors testified that they had seen the shackles or heard comments about them, and then sent the case back to the lower courts. The lower court again determined that the shackles did not affect the verdict, and the appellate court agreed with the state once again, and the Michigan Supreme Court denied an appeal.
Davenport then challenged his conviction in the federal courts. The district court refused to hear the case. He then petitioned the U.S. Court of Appeals for the 6th Circuit, which agreed the hear the case. This appeals court cited the ''
Deck v. Missouri
''Deck v. Missouri'', 544 U.S. 622 (2005), was a Supreme Court of the United States, United States Supreme Court case that dealt with the constitutionality of shackling a prisoner during the sentencing phase of a trial. In a 7–2 opinion deliver ...
'' decision, and quoted from ''Holbrook v. Flynn'': "shackling is inherently prejudicial". The court found that the state had not met the burden of proof necessary to show that the jury was not influenced by the shackling, and provided
habeas relief
''Habeas corpus'' (; from Medieval Latin, ) is a recourse in law through which a person can report an unlawful detention or imprisonment to a court and request that the court order the custodian of the person, usually a prison official, t ...
, over the dissent of Judge
Chad Readler
Chad Andrew Readler (; born August 23, 1972) The state attempted to have the decision stayed, but the court declined.