## Facts

- Ervine Davenport was convicted in Michigan of first-degree murder after killing Annette White; he testified he acted in self-defense during a struggle while driving.
- Physical evidence and inconsistencies in Davenport’s account supported the prosecution’s theory of intentional killing.
- At trial, Davenport was restrained with wrist, waist, and ankle shackles while seated behind a “privacy screen” intended to block the jury’s view.
- On direct review, the Michigan Supreme Court found a due process violation because the record did not show a special need for shackling, and it remanded for harmless-error review under the “harmless beyond a reasonable doubt” standard.
- After an evidentiary hearing that included juror testimony, the state trial court found the shackling error harmless beyond a reasonable doubt; state appellate courts affirmed.
- Davenport sought federal habeas relief under 28 U.S.C. § 2254; the federal district court denied relief under AEDPA deference.
- The Sixth Circuit reversed, treating the case as governed only by Brecht’s “substantial and injurious effect” standard and granting relief without applying AEDPA’s § 2254(d).

## Issues

1. When a state court has adjudicated a constitutional trial-error claim on the merits, may a federal habeas court grant relief based solely on Brecht’s “substantial and injurious effect” test?
2. Or must the habeas court also find that the state court’s harmless-error decision was unreasonable under AEDPA, 28 U.S.C. § 2254(d)?

## Decision

- The Supreme Court reversed the Sixth Circuit.
- A federal habeas court may not grant relief on a claim adjudicated on the merits in state court unless the petitioner satisfies both Brecht and AEDPA § 2254(d).
- The Sixth Circuit erred by granting relief after applying only Brecht and declining to analyze AEDPA.
- Applying AEDPA, the Court concluded Davenport did not show the state courts’ harmless-error determination was unreasonable; AEDPA therefore barred relief.

## Legal Principles

- If a state court adjudicated a claim on the merits, § 2254(d) restricts federal habeas relief unless the state decision was contrary to, or an unreasonable application of, clearly established federal law, or rested on an unreasonable determination of facts.
- Brecht’s “substantial and injurious effect or influence” test for trial error on collateral review is an additional requirement; it does not replace AEDPA.
- Because AEDPA and Brecht ask different questions (state-court reasonableness versus actual prejudicial effect), both inquiries can be required before relief may issue.
- A federal habeas court must deny relief if the petitioner fails AEDPA § 2254(d), even if the court believes the petitioner could meet Brecht.

## Conclusion

The Court held that when state courts have decided a trial-error claim on the merits, a federal habeas court can grant relief only if the petitioner satisfies both Brecht’s prejudice standard and AEDPA’s deferential limits on relitigation of the claim, and it reinstated the denial of Davenport’s habeas petition.


Brown v. Davenport, 596 U.S. 118 (2022)