## Facts

- Robert Keith Woodall pleaded guilty in Kentucky state court to capital murder, capital kidnapping, and first-degree rape of a sixteen-year-old girl.
- The rape conviction served as the statutory aggravating circumstance supporting the capital murder charge.
- At the capital penalty phase, Woodall presented mitigation testimony from multiple witnesses but did not testify.
- Woodall requested a jury instruction that no adverse inference may be drawn from his failure to testify (a no-adverse-inference instruction).
- The trial court denied the request; the jury recommended death, and the court imposed a death sentence.

## Issues

1. Whether, under 28 U.S.C. § 2254(d)(1), it was contrary to or an unreasonable application of clearly established Supreme Court law for the Kentucky Supreme Court to reject Woodall’s claim that the Fifth Amendment required a requested no-adverse-inference instruction at the capital penalty phase following a guilty plea.

## Decision

- The U.S. Supreme Court reversed the Sixth Circuit’s grant of habeas relief.
- The Court held that the Kentucky Supreme Court’s decision was not an objectively unreasonable application of clearly established Supreme Court precedent under AEDPA.
- The Court emphasized that § 2254(d)(1) does not require state courts to extend Supreme Court precedent and does not permit federal habeas courts to treat a failure to extend precedent as error.
- Because existing Supreme Court holdings did not directly require a no-adverse-inference instruction in the specific penalty-phase context presented, habeas relief was unavailable.

## Legal Principles

- Under AEDPA, federal habeas relief may be granted only if the state court decision is contrary to, or involves an objectively unreasonable application of, clearly established Supreme Court holdings.
- “Clearly established Federal law” for § 2254(d)(1) means Supreme Court holdings, not dicta, and does not include rules that would require extending precedent to new contexts.
- A state court’s decision must be beyond fairminded disagreement to qualify as an objectively unreasonable application of clearly established law.
- Supreme Court cases requiring a no-adverse-inference instruction at the guilt phase, or prohibiting adverse inferences from silence in certain sentencing factfinding, did not clearly establish a requirement for the requested instruction at a capital penalty phase after a guilty plea to the aggravating circumstance.

## Conclusion

The Supreme Court held that AEDPA barred federal habeas relief because no Supreme Court holding clearly required a no-adverse-inference jury instruction at the capital penalty phase in Woodall’s circumstances, and the state court’s refusal to extend existing precedent was not objectively unreasonable.


White v. Woodall, 572 U.S. 415 (2014)