Woods v. Donald

Background

Cory Donald was convicted in Michigan of felony murder and armed robbery after a home robbery left a victim dying. He was tried with codefendants. At trial, his lawyer said the prosecution’s phone-call evidence did not affect his client, briefly left the courtroom during that testimony, and returned about ten minutes later. The jury convicted Donald and Michigan appellate courts rejected his claim of ineffective assistance. A federal district court granted habeas relief and the Sixth Circuit affirmed.

Reasoning

The central question was whether this Court’s Cronic decision — which allows courts to presume prejudice when a defendant is denied counsel at a critical stage — clearly requires automatic relief for a short lawyer absence during testimony about other defendants. Under the federal habeas law (AEDPA), relief is allowed only when a state court’s decision is contrary to or an unreasonable application of this Court’s holdings. The Court said no prior decision of this Court clearly holds that Cronic applies to these facts, so the Michigan court’s ruling was not unreasonably wrong. The Supreme Court therefore reversed the Sixth Circuit and denied habeas relief.

Real world impact

The ruling makes it harder for state prisoners to get federal habeas relief based on a brief attorney absence during testimony about codefendants. It reinforces deference to state appellate decisions under AEDPA and signals that short absences, especially when counsel had said the evidence was irrelevant, will not automatically trigger a presumption of prejudice. The Court emphasized this decision addresses only habeas-review standards and does not resolve the broader Sixth Amendment question on the merits.