Mays v. Hines
The Supreme Court reversed a federal appeals court that had ordered a new trial for a man convicted of a 1985 murder, finding that the Sixth Circuit improperly ignored a mountain of evidence against the defendant while speculating that someone else might have committed the crime.
The decision reinforces the strict limits Congress placed on federal courts reviewing state criminal convictions: a federal court cannot substitute its own judgment for the state court's unless the state court's decision was so unjustifiable that no reasonable jurist could defend it.
How it got here: Hines sought post-conviction relief in Tennessee state courts and was denied; he then filed a federal habeas petition; the Sixth Circuit reversed and granted him a new trial; the warden petitioned the Supreme Court, which granted review and reversed.
The Case in Depth
What happened
A Tennessee jury convicted Anthony Hines of murdering Katherine Jenkins, a motel maid, in 1985. The evidence against him was extensive: witnesses saw him flee in her car wearing a bloody shirt; family members heard him admit to stabbing someone at the motel; he gave investigators multiple contradictory stories; and police found the victim's wallet where he had abandoned her car. Decades later, Hines argued his trial lawyer was ineffective for not more aggressively accusing Kenneth Jones — the man who discovered the body — of committing the murder instead.
The question before the Court
Can a federal appeals court grant a murder convict a new trial 35 years later by theorizing an alternative suspect — while ignoring the overwhelming evidence of guilt that led the state court to deny relief?
The Court's answer
No — the Sixth Circuit had no business ordering a new trial on these facts. Under the federal habeas statute (28 U.S.C. § 2254(d)), a federal court can override a state court's denial of post-conviction relief only when the state court's decision was so unreasonable that no fair-minded judge could defend it — a standard far more demanding than simply disagreeing with the outcome.
The Tennessee court reasonably concluded that Hines was not harmed by his lawyer's decision not to pin the murder on Jones, given the enormous weight of evidence pointing to Hines himself. The Sixth Circuit never engaged with that evidence; it focused only on ways Jones could theoretically be cast as a suspect while overlooking Hines' bloody shirt, the victim's car and wallet in his possession, and his contradictory confessions. That one-sided approach is precisely what federal habeas review forbids.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
People convicted of crimes in state court face a very high wall when they try to challenge those convictions in federal court decades later. This ruling makes clear that federal judges must grapple with all the evidence supporting the state court's decision — not just the facts that favor the defendant — before concluding a state court was wrong enough to justify undoing a conviction.
What changes now
The Sixth Circuit's order for a new trial is undone, and Anthony Hines' Tennessee murder conviction stands. This is a final merits decision — there is no remand for further proceedings. The Supreme Court reinstated the state court's judgment directly, so the case is over in federal court.
What this does not decide
The ruling does not decide whether Hines' trial lawyer was actually ineffective — only that the Tennessee court's finding of no prejudice was not unreasonably wrong. It also does not address whether federal habeas relief could ever be appropriate in cases with similarly strong evidence of guilt.
Concurrences and dissents
Dissent — Justice Sotomayor
Justice Sotomayor noted her dissent without a written opinion, so the specific grounds for her disagreement are not stated in the opinion text.
How the Court got there
The legal reasoning, step by step
- The Court began with the governing standard under 28 U.S.C. § 2254(d) — the federal habeas statute that limits when federal courts can disturb a state court's ruling. A federal court may grant relief only if the state court's decision was 'unreasonable,' meaning not merely incorrect or debatable, but so wrong it lies beyond any possibility for fair-minded disagreement. The bar is intentionally high to respect states' authority over their own criminal justice systems.
- Hines' claim was for ineffective assistance of counsel under Strickland v. Washington (1984), which requires proving both that the lawyer's performance fell short and that the errors were serious enough to have likely changed the outcome — the 'prejudice' prong. A state court rejecting a Strickland claim gets extra deference on federal habeas review: a federal court must find the state court's application of Strickland was not just wrong, but unreasonably so.
- For a federal court to legitimately call a state court's reasoning 'lacking in justification,' it must first identify and rebut all the reasons and evidence supporting the state court's conclusion. Omitting inconvenient facts amounts to evaluating the case from scratch — exactly the kind of de novo (from the beginning) review Congress prohibited.
- The Sixth Circuit failed that test. In its 10-page analysis, the majority never grappled with the evidence tying Hines to the crime — his flight in a blood-stained shirt, possession of the victim's car, keys, and wallet, his recurring use of knives, or his shifting stories about imaginary attackers. It focused exclusively on how counsel might have cast Jones as an alternative suspect.
- The Tennessee court's conclusion that blaming Jones would have been 'farfetched' was fully reasonable: Jones had discovered and reported the body in a public place where he was known to the staff and in the presence of his companion; and Jones' testimony said nothing about Hines' guilt. Impeaching Jones would not have moved the needle on the substantial evidence pointing directly at Hines.
- Because the Sixth Circuit never engaged with the full record and simply substituted its own speculation for the state court's reasoned judgment, its grant of habeas relief violated the demanding standard Congress set — and the Supreme Court reversed.
Doctrinal impact
Cases affected by this decision
Reaffirms Harrington v. Richter (562 U. S. 86)
Reaffirms that federal habeas relief requires showing a state court error beyond any possibility of fair-minded disagreement.
Reaffirms Strickland v. Washington (466 U. S. 668)
Reaffirms that defendants must show counsel's errors likely changed the outcome to win an ineffective-assistance claim.