Woods v. Donald

**Question presented** Did the Sixth Circuit correctly grant federal habeas relief by saying that Cory Donald’s lawyer’s brief absence while the government was questioning a co‑defendant automatically violated Donald’s Sixth‑Amendment right to effective assistance of counsel under *United States v. Cronic*? **Holding** No. The Supreme Court reversed the Sixth Circuit. It held that the Michigan Court of Appeals’ decision was **not** contrary to, and was not an unreasonable application of, any clearly‑established Supreme Court rule. Therefore the federal court could not grant Donald habeas relief. **Why the Court reached that result** *Plain‑English explanation of the legal framework* - **Habeas corpus** is a court order that lets a prisoner challenge the legality of his confinement. - Under the **Antiterrorism and Effective Death Penalty Act** (AEDPA), a federal court may grant such relief only if a state court’s decision is either (1) *contrary to* a clear Supreme Court rule, or (2) an *unreasonable* application of that rule. The standard is deliberately very high. *What the Supreme Court said* 1. **What *Cronic* actually requires** – The Court’s earlier case *Cronic* says a defendant can be presumed prejudiced only when counsel is **totally absent** at a “critical stage” of the trial (a stage that “has significant consequences for the accused”). It does **not** create a blanket rule that any brief absence, especially when the testimony does not directly involve the defendant’s own case, triggers automatic prejudice. 2. **No clear precedent covering Donald’s situation** – The Court noted that none of its past decisions address a scenario where a lawyer steps out while the prosecution is questioning a co‑defendant about that co‑defendant’s own actions. Because the existing holdings do not speak to this exact question, the state court’s decision cannot be considered “contrary to” Supreme Court law. 3. **The Sixth Circuit’s “similar to” reasoning isn’t enough** – The Sixth Circuit said the testimony was “similar” to other cases that the Court had called critical stages. The Supreme Court explained that “similar” is not the same as “the same,” and a decision that is merely analogous does not make the state court’s ruling contrary to a binding holding. 4. **No unreasonable application** – Even if the Sixth Circuit treated the testimony as a critical stage, that view was not an “objectively unreasonable” application of the law because the Court has never said that brief, non‑essential absences during unrelated testimony fall within *Cronic*’s presumption of prejudice. Because the state court’s decision did not violate a clear Supreme Court rule, the federal habeas court lacked the authority to overturn it, and the Supreme Court therefore reversed the Sixth Circuit’s grant of relief. **Vote and dissent** The opinion is *per curiam* (issued in the name of the Court rather than a single justice). No vote count or dissenting opinions were provided in the text, so none can be reported.