安德鲁诉怀特案

On November 20, 2001, Rob Andrew was fatally shot in his garage in Oklahoma. His estranged wife, Brenda Andrew, was also shot in the arm and initially told police two armed assailants committed the shooting. She soon traveled to Mexico with her romantic partner James Pavatt. Pavatt later confessed to the shooting but denied Brenda's involvement. Both were charged with capital murder. An Oklahoma jury convicted Brenda Andrew of murdering her husband and sentenced her to death. During her 2004 trial, the prosecution introduced extensive irrelevant evidence about her sex life, attire, and failings as a mother and wife. After state appeals failed, Andrew filed a federal habeas petition arguing the evidence violated the Due Process Clause. The Tenth Circuit denied relief, finding she had not identified "clearly established federal law". The Supreme Court granted certiorari and issued its decision on January 21, 2025.

The Supreme Court vacated the Tenth Circuit's judgment and remanded the case in a 7-2 per curiam decision. The Court held that clearly established federal law provides that the Due Process Clause forbids the introduction of evidence so unduly prejudicial as to render a criminal trial fundamentally unfair. The Court clarified that this principle was a holding of Payne v. Tennessee, not mere dicta. Justice Alito filed an opinion concurring in the judgment. Justice Thomas filed a dissenting opinion, joined by Justice Gorsuch.

Whether the Tenth Circuit erred in holding that no "clearly established federal law" prohibited the introduction of unduly prejudicial evidence at a criminal trial. Specifically, whether the Due Process Clause forbids the introduction of evidence so unduly prejudicial as to render a criminal trial fundamentally unfair, and whether this principle was a "holding" of the Supreme Court in Payne v. Tennessee for purposes of AEDPA.

The decision clarified that the Due Process Clause provides protection against unduly prejudicial evidence in criminal trials. The case has been cited in a growing range of cases alleging that prejudice, bias, or fundamentally unfair tactics tainted criminal proceedings. Legal commentators noted the case addressed prosecutorial use of sexual stereotypes against female defendants, particularly in capital cases. The ruling also provided important guidance on AEDPA's "clearly established federal law" requirement. On remand, Brenda Andrew was again denied relief.