Scott Kernan, Secretary, California Department of Corrections and Rehabilitation v. Antonio A. Hinojosa (578 U.S. 412)
U.S. Supreme Court · decided May 16, 2016 · Supreme Court Database (Spaeth)
- Citation
- 578 U.S. 412 · 136 S. Ct. 1603
- Decided
- May 16, 2016
- Term
- October Term 2015
- Vote
- 6–2
- Issue area
- Criminal Procedure
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
PER CURIAM. The Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) requires a state prisoner seeking federal habeas relief first to "exhaus[t] the remedies available in the courts of the State." 28 U.S.C. § 2254(b)(1)(A). If the state courts adjudicate the prisoner's federal claim "on the merits," § 2254(d), then AEDPA mandates deferential, rather than de novo, review, prohibiting federal courts from granting habeas relief unless the state-court decision "was contrary to, or involved an unreasonable application of, clearly established Federal law," § 2254(d)(1), or "was based on an unreasonable determination of the facts," § 2254(d)(2). The Ninth Circuit in this case decided that the Supreme Court of California's summary denial of a habeas petition was not "on the merits," and therefore AEDPA's deferential-review provisions did not apply. We summarily reverse. Respondent Antonio Hinojosa was serving a 16-year sentence for armed robbery and related crimes when, in 2009, California prison officials "validated" him as a prison-gang associate and placed him in a secured housing unit. At the time of Hinojosa's offense and conviction, California law had permitted prisoners placed in a secured housing unit solely by virtue of their prison-gang affiliations to continue to accrue good-time credits. See Cal.Penal Code Ann. § 2933.6 (West 2000). In 2010, the California…
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