Mays v. Hines: Federal habeas courts cannot disregard state court’s findings that evidence of guilt was overwhelming
A federal habeas court cannot disregard a state court’s finding denying postconviction relief on grounds that evidence of guilt was overwhelming, the U.S. Supreme Court held March 29 in Mays v. Hines.
Anthony Hines was convicted of a motel murder near Nashville, Tennessee. The victim, a motel maid, was found stabbed to death a few hours after Hines checked in. Her wallet, car keys and car were missing.
Later on the afternoon of the murder, Hines was found with the victim’s car, which was broken down along a road. A group of travelers offered him a ride. The travelers noticed Hines had blood on his shirt, seemed “nervous,” and told contradictory stories about himself and the car.
Hines returned to his family’s residence. His sister noticed blood on his shirt. Hines said he had stabbed a male victim who had assaulted him at the motel. Hines had the maid’s car keys. Hines said he got the keys from a different man who tried to rob Hines.
Hines eventually surrendered to police. He told police he took the victim’s car but didn’t kill her. He later changed his story and offered to confess if he would not be charged with the death penalty.
Police found the victim’s wallet where Hines had abandoned her car.
At trial, the defense claimed the man who had discovered the body, Kenneth Jones, committed the murder – not Hines. Jones testified he knew the owners of the motel and had stopped by that afternoon, but finding no one in the motel office, took a room key and went to a room to use the bathroom, where he found the body.
The defense argued Jones was “nervous,” that “there was a lot of something going on,” and that Jones’ story didn’t match the timeline given by first responders.
The jury found Hines guilty.
Hines sought postconviction review in Tennessee courts. There, he presented evidence that Jones had been at the motel for an affair with a woman other than his wife. Jones and the woman had stayed at the motel nearly every week for two years, and were well-known by motel staff.
Jones had helped himself to a room key to check in. Upon finding the body, Jones called police, then drove his companion home, before returning to the motel.
Hines’ trial attorney was aware of Jones’ affair, but had decided not to present details at Hines’ trial in order to spare Jones embarrassment.
Hines claimed his attorney had been ineffective in failing to present the full picture of why Jones was at the motel to support the defense that Jones committed the murder.
The Tennessee courts denied Hines’ claim, finding no prejudice since the evidence of guilt was strong, and that although Jones told an “evolving story” of events, his true reason for being at the motel had “little relevance” to Hines’ conviction.
On federal habeas review, the Sixth Circuit reversed. The Sixth Circuit ruled that better defense investigation could have cast doubt on Jones’ story and undermined his credibility. The court did not analyze evidence of Hines’ guilt.
The Supreme Court, in an 8-1 per curiam opinion, reversed.
A federal habeas court cannot grant relief under Section 2254(d) unless the state court’s decision took an “unreasonable” view of the facts or law, the Court said.
“The term ‘unreasonable’ refers not to ‘ordinary error’ or even to circumstances where the petitioner offers ‘a strong case for relief,’ but rather to ‘extreme malfunctions in the state criminal justice system,’” the Court said. The state court’s decision must be “so lacking in justification … beyond any possibility for fairminded disagreement.”
“If this rule means anything, it is that a federal court must carefully consider all the reasons and evidence supporting the state court’s decision,” the Court said.
“Nowhere in its 10-page discussion of Hines’ theory did the [Sixth Circuit] consider the substantial evidence linking him to the crime,” the Court said. The Sixth Circuit “instead focused on all the reasons why it thought Jones ‘could have’ been a viable alternative suspect.”
“Had the Sixth Circuit properly considered the entire record, it would have had little trouble deferring to the Tennessee court’s conclusions that Hines suffered no prejudice,” the Court concluded. The Tennessee court had not “blunder[ed] so badly that every fairminded jurist would disagree.”
Justice Sotomayor dissented, without opinion.