Apr. 21, 2022 – Brown v. Davenport (U.S. Supreme Ct., 20-826)

To obtain federal habeas relief, a state petitioner must satisfy two distinct prejudice tests: (1) the alleged constitutional violation must have had a “substantial and injurious effect or influence” under Brecht v. Abrahamson (1993) 507 U.S. 619; and (2) the state court’s application of the harmless error standard of Chapman v. California (1967) 386 U.S. 18 must have been unreasonable under AEDPA. The U.S. Supreme Court rejects the Sixth Circuit’s view that satisfaction of the Brecht test alone is sufficient.