Shoop v. Hill

The U.S. Supreme Court decided Shoop v. Hill on January 7, 2019. Ohio death row inmate Danny Hill was convicted of the 1985 murder of 12-year-old Raymond Fife. Hill claimed he was intellectually disabled and thus ineligible for execution under Atkins v. Virginia. The Sixth Circuit granted habeas relief, finding state courts unreasonably determined Hill failed to prove disability. Warden Tim Shoop appealed. The Supreme Court reversed in a unanimous per curiam opinion, holding that the Sixth Circuit violated the AEDPA by failing to accord proper deference to state court factual findings. The Court emphasized federal courts may not substitute their own judgment merely because they would have weighed evidence differently. The case was remanded.

The Supreme Court unanimously reversed the Sixth Circuit, holding that the appellate court failed to apply the highly deferential AEDPA standard and improperly re-weighed evidence, and remanded the case for further proceedings.

Whether the Sixth Circuit violated the AEDPA by refusing to defer to the state court's conclusion that Danny Hill did not demonstrate intellectual disability, thereby improperly granting federal habeas relief.

The ruling reinforced strict limits on federal habeas review of state factual findings in death penalty cases, especially intellectual disability claims. It underscored that federal courts must not re-evaluate evidence and must give state courts the benefit of the doubt under AEDPA. This made it more difficult for death-row inmates to succeed on Atkins claims in federal court and strengthened states’ authority in finalizing executions.