Case No. 16-6855 | 11th Cir. Decision
In 1996, nineteen-year-old Marion Wilson and his friend, Robert Butts, solicited a ride from their later victim, Donovan Parks, an off-duty state correctional officer in Georgia. Mr. Butts sat in front while Mr. Wilson sat in the back. Mr. Butts allegedly killed Mr. Parks with a sawed-off shotgun, a story told by Mr. Wilson and corroborated by numerous inmates who claimed Mr. Butts confessed in prison.
The prosecutor offered Mr. Wilson a plea deal with eligibility for parole in twenty years but Mr. Wilson rejected it, believing he should at least receive a mitigated sentence at trial. Unfortunately for Mr. Wilson, his counsel at trial did an incredibly poor job. Between their conflicts (one of his attorneys accepted an appointment with the Georgia Attorney General’s office during the trial), complete ignorance (neither had death penalty experience, despite representing that they did), and multiple missed opportunities (both said that it was not their responsibility to put on a mitigation investigation), Mr. Wilson stood little chance for release or even a mitigated sentence, for that matter. In briefs filed with the court, Mr. Wilson’s defense counsel wrote a mere 23 pages compared with the prosecution’s 324 pages. Defense counsel neglected to introduce helpful witnesses or provide even fairly simple mitigation evidence.
In reaction to his counsel’s deficiencies, Mr. Wilson filed for state habeas relief, specifically identifying his counsel’s failure to investigate, develop, and present available mitigating evidence. The state habeas court rejected Mr. Wilson’s claim. On appeal, the Georgia Supreme Court denied a Certificate of Probable Cause (a necessity in appealing a state habeas denial) in a one-sentence decision.
Mr. Wilson then worked his way through the federal appeals process, first requesting habeas relief from the district court, which denied relief. The Eleventh Circuit affirmed, concluding that the Georgia Supreme Court’s one-line decision was the final decision on the merits and thus, the relevant decision for its review. A rehearing en banc was granted, in which a 6-5 majority agreed with the panel’s decision. Finally, the Court granted cert to decide whether the federal appellate courts looked at the proper state court decision in denying relief to Mr. Wilson.
In order to answer this question, the Court will have to look at the Antiterrorism and Effective Death Penalty Act (“AEDPA”) of 1996 and relevant case law. Congress enacted the AEDPA with the intention of making state court decisions the central focus of federal habeas review. This is complicated, however, by the fact that state appellate courts will sometimes only provide short, conclusory opinions lacking any rationale. Mr. Wilson claims that the federal courts should have used “look through” methodology (applied in Ylst v. Nunnemaker, 501 U.S. 797 (1991)) when ascertaining the rationale behind the state appellate court’s decision. Thus, Mr. Wilson says, the Eleventh Circuit should have looked at the state trial court’s more reasoned decision rather than the one sentence provided by the Georgia Supreme Court.
Respondent, in contrast, argues that the statute governing state habeas, 28 U.S.C. § 2254(d), requires deference to the last state court’s decision even if it did not provide reasons for its decision. From the standard provided in Harrington v. Richter, 562 U.S. 86 (2011), the federal court may only grant relief if no reasonable basis could have supported the state court’s decision. The Respondent further argues that the AEDPA does not allow for the “look through” approach advocated by Mr. Wilson. Thus, the Respondent claims, the Eleventh Circuit was correct in only asking whether any reasonable basis could have supported the state appellate court’s one-line decision.