Shinn v. Kayer

In 1994, George Russell Kayer murdered Delbert Haas during a gambling trip in Laughlin, Nevada, shooting him in the head and later returning to shoot him again to retrieve forgotten keys. Kayer was convicted of premeditated first-degree murder in Arizona and sentenced to death after the judge found two aggravating factors and one non-statutory mitigator. In post-conviction proceedings, Kayer claimed ineffective assistance of counsel, arguing his attorneys failed to investigate mitigating circumstances such as addictions and mental illness. The Arizona courts rejected this claim. The Ninth Circuit reversed, granting habeas relief, but the U.S. Supreme Court vacated that decision, holding the Ninth Circuit failed to properly defer to the state court under AEDPA.

The Supreme Court, in a 6-3 per curiam opinion, vacated the Ninth Circuit's judgment and remanded the case, holding that the Ninth Circuit violated AEDPA jurisprudence by essentially evaluating the merits de novo and failing to afford the state court the required deference. Justices Breyer, Sotomayor, and Kagan dissented.

Whether the Ninth Circuit erred in granting federal habeas corpus relief by failing to apply the deferential standard of review required by the Antiterrorism and Effective Death Penalty Act (AEDPA) to the Arizona state court's rejection of Kayer's ineffective assistance of counsel claim.

The decision reinforced the strict deferential standard that federal habeas courts must apply to state court decisions under AEDPA, making it more difficult for death-row inmates to obtain federal relief based on ineffective assistance of counsel claims. It sparked debate about the balance between finality in capital cases and the Sixth Amendment right to adequate legal representation.