Lopez v. Smith

Background

Marvin Smith was tried and convicted of first‑degree murder for the death of his wife, Minnie Smith, after evidence tied his DNA and belongings to the crime scene and missing jewelry was found in his car. At trial the prosecutor sought an aiding‑and‑abetting jury instruction; the jury convicted without specifying which theory it relied on. State courts affirmed the conviction. Smith then sought federal court review of his conviction, and the District Court and Ninth Circuit granted him relief, concluding he lacked adequate notice that he could be convicted as an aider and abettor because the prosecution had focused on the theory that he delivered the fatal blow.

Reasoning

The central question was whether a federal appeals court may grant federal review because a prosecutor emphasized one theory at trial despite earlier notice of another theory. The Court explained that federal habeas relief may be granted only when a state court's decision is contrary to or an unreasonable application of clearly established federal law as set by this Court. The Ninth Circuit relied on its own past decision rather than any Supreme Court case establishing the rule Smith needed. Under the controlling federal law, circuit courts may not create the “clearly established” rules required to overturn state court decisions, so the Ninth Circuit’s grant of relief could not stand.

Real world impact

The Court reversed the Ninth Circuit and sent the case back for further proceedings consistent with this opinion. The ruling underscores that federal appeals courts cannot supply new Supreme Court rules to justify habeas relief and limits when federal courts can overturn state convictions based on circuit precedent.