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Brown v. Davenport

596 U.S. 118 (2022)

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Brown v. Davenport

United States Supreme Court
596 U.S. 118 (2022)

RW

Facts

A jury found Ervine Davenport (defendant) guilty of murder. A Michigan appellate court affirmed, after conducting a Chapman v. California review and ruling that shackling Davenport throughout his trial was only harmless error. Davenport petitioned for federal habeas corpus relief. A federal district court reviewed the Michigan appellate court’s ruling under the federal Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) and found no error. The Sixth Circuit reversed. The circuit court declined to apply the AEDPA and ruled that Davenport satisfied the Brecht v. Abrahamson test for habeas corpus relief. Michigan prison warden Mike Brown appealed to the Supreme Court, which granted certiorari to resolve a circuit split as to the interplay between Chapman, Brecht, and the AEDPA.

Rule of Law

Issue

Holding and Reasoning (Gorsuch, J.)

Dissent (Kagan, J.)

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