Supreme Court Decides Parker v. Matthews
On June 11, 2012, the U.S. Supreme Court granted certiorari in Parker v. Matthews, (No. 11-845), and summarily reversed without argument the Sixth Circuit's decision to grant habeas relief to a defendant convicted of two counts of murder. The Court wrote that habeas relief had been granted "based on the flimsiest of rationales" and held that the Sixth Circuit had failed to properly apply the deferential standard of review required by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).
A Kentucky jury found David Eugene Matthews guilty of murdering his estranged wife and mother-in-law, and he was sentenced to death. At trial, Matthews did not contest that he killed the victims but invoked a defense of "extreme emotional disturbance" that, if proven, could have reduced the convictions to a lesser degree of culpability. The Kentucky Supreme Court affirmed his convictions and sentence. Matthews' petition for habeas relief was dismissed by the district court, but the Sixth Circuit reversed with instructions to grant relief. The Sixth Circuit asserted that two errors had occurred: (1) the Kentucky Supreme Court had impermissibly shifted the burden of proving extreme emotional disturbance to Matthews, and the Commonwealth had failed to prove the absence of extreme emotional disturbance beyond a reasonable doubt; and (2) remarks made by the prosecutor during closing argument resulted in a denial of Matthews' due process rights.
The Supreme Court held that neither of the Sixth Circuit's assertions of error was a valid reason to grant habeas relief under AEDPA. As to the first asserted error, the Court concluded that the Kentucky Supreme Court had invoked "a ground of questionable validity" relating to the assignment of the burden of proof, but that remark was "irrelevant" because "[t]he case had been submitted to the jury with the burden assigned to the Commonwealth, the jury had found that burden carried, and the Kentucky Supreme Court found the evidence adequate to sustain that finding." The Court also rejected the Sixth Circuit's conclusion that the evidence did not support a finding of no extreme emotional disturbance, noting that the standard was "twice-deferential" and sufficient evidence existed as to the jury's convictions and the state court's decision to uphold that conviction.
As to the second asserted error, the Sixth Circuit had concluded that a prosecutor's remarks suggesting collusion between the attorney and the defendant amounted to a denial of Matthews' due process rights. The Court found, however, that no Supreme Court precedent "prohibits a prosecutor from emphasizing a criminal defendant's motive to exaggerate exculpatory facts." Even if the prosecutor's comments had been improper, the defendant's constitutional rights are violated only if the remarks "so infected the trial with unfairness as to make the resulting conviction a violation of due process." The Supreme Court of Kentucky had concluded that the remarks did not meet the standard, and "the Sixth Circuit had no warrant to set aside the Kentucky Supreme Court's decision." Accordingly, the Court reversed the opinion of the Sixth Circuit.
The Court's per curiam decision was unanimous.