Brown v. Davenport | Case No. 20-826 | Date Argued: 10/5/2021 | Date Decided: 4/21/2022

Background: In Brecht v. Abrahamson, 507 U.S. 619 (1993), the Court held that the test for determining whether a constitutional error was harmless on habeas review is whether the error had a "substantial and injurious effect or influence" on the verdict. Later, in Chapman v. California, 386 U.S. 18 (1967), the Court held that, in addition to satisfying Brecht, a habeas petitioner must satisfy the requirements of the Antiterrorism and Effective Death Penalty Act (AEDPA). AEDPA provides that federal courts cannot grant habeas relief unless the state court's decision "was contrary to, or involved an unreasonable application of, clearly established Federal law."

Question Presented: May a federal habeas court grant relief based solely on its conclusion that the Brecht test is satisfied, or must the court also find that the state court's Chapman application was unreasonable under AEDPA?

Holding: [NO INFORMATION]

Result: Judgment REVERSED.

Voting Breakdown: 6-3. Justice Gorsuch delivered the opinion of the Court, in which Chief Justice Roberts and Justices Thomas, Alito, Kavanaugh and Barrett joined. Justice Kagan filed a dissenting opinion, in which Justices Breyer and Sotomayor joined.

Link to Opinion: Here.

Oral Advocates:

For Petitioner: Fadwa A. Hammoud, Solicitor General, Lansing, Mich. For Respondent: Tasha Bahal, Boston, Mass.