Carey v. Musladin (2006)
- Docket
- 05-785
- Decided
- 2006-01-01
Summary
Question: Did the Ninth Circuit exceed its authority under 28 U.S.C. Section 2254(d)(1) when it overturned a murder conviction because the victim's family members appeared in the Courtroom wearing buttons with pictures of the victim? Conclusion: Yes. In a unanimous decision written by Justice Clarence Thomas, the Court reversed the Ninth Circuit and ruled that the state court's decision was not an unreasonable application of any clearly established Supreme Court precedent. The Court did not explicitly say that Circuit Courts cannot cite their own Circuit precedents when granting habeas relief, but the Court only addressed the Supreme Court precedents cited by the Ninth Circuit. Those precedents only dealt with government-sponsored practices that may prejudice a jury, such as forcing a defendant to appear in court wearing prison clothing. The Court's opinion called the issue of spectator conduct, like the kind at issue in Musladin's trial, an "open question in our jurisprudence." Since there was no clearly established federal law on the issue of spectator conduct, the Court held that the Ninth Circuit was wrong to grant habeas relief and overturn Musladin's conviction.