Harrington v. Richter

Background

Joshua Richter, a man convicted in California of murder and related charges, challenged his conviction in state and federal courts. The case turned on competing accounts of a 1994 double shooting, blood evidence, and defense counsel's choice not to consult forensic blood experts. The California Supreme Court denied Richter's state habeas petition in a one-sentence order. A federal district court and a Ninth Circuit panel denied relief, but the Ninth Circuit sitting en banc later granted federal habeas relief, finding counsel ineffective. The Supreme Court agreed to review whether federal habeas law limits apply when a state court issues a summary denial and whether the appeals court properly reviewed the ineffective-assistance claim.

Reasoning

The Court held that the federal habeas statute that limits relitigation after state rulings applies even when a state court issues a one-line denial, and that federal courts must give state-court decisions room for reasonable disagreement. The Court explained that the en banc Ninth Circuit applied de novo review and failed to ask whether fair-minded jurists could agree with the state court's outcome under the governing ineffective-assistance standard. Because the Ninth Circuit did not show the state court's decision was beyond any fairminded disagreement, the Supreme Court reversed and sent the case back.

Real world impact

The ruling strengthens the finality of state-court decisions and makes it harder for people in state custody to win federal habeas relief after a summary state denial. It emphasizes that federal judges must respect reasonable state-court outcomes and not substitute their own judgment. This decision does not decide whether counsel's choices were actually ineffective under the criminal standard; it resolves the proper federal review method.

Dissents or concurrances

Justice Ginsburg concurred in the judgment, agreeing counsel likely failed to consult experts but finding no substantial effect on the trial's outcome.