Jenkins v. Hutton

Raymond A. Jenkins was convicted of aggravated murder and sentenced to death for shooting store clerk Eddie Tucker during a 1989 robbery in Ohio. After exhausting state remedies, Jenkins sought federal habeas corpus relief, arguing his trial counsel had been ineffective by failing to investigate and present substantial mitigating evidence regarding his background and mental health. The district court and the U.S. Court of Appeals for the Sixth Circuit held that the claim was procedurally defaulted because it had not been properly raised in state court. The lower courts further rejected Jenkins’s attempt to pass through the actual-innocence gateway, finding the new evidence insufficient. The U.S. Supreme Court granted certiorari and, in a per curiam opinion issued on June 19, 2017, summarily reversed the Sixth Circuit, clarifying that the court of appeals had applied an overly stringent standard for gateway innocence claims.

The U.S. Supreme Court reversed and remanded in a per curiam decision, holding that the court of appeals conflated the standard for a gateway innocence claim with that of a substantive freestanding innocence claim, and directed the lower court to reconsider the claim under the proper standard.

Whether the Sixth Circuit applied an incorrect legal standard when it rejected Jenkins's gateway actual-innocence claim, effectively requiring a showing sufficient for a freestanding innocence claim rather than the lower threshold required to overcome procedural default under Schlup v. Delo.

The decision reinforced the distinction between gateway actual-innocence claims and freestanding innocence claims in federal habeas proceedings, ensuring that procedural default rules do not improperly foreclose review of potentially meritorious constitutional violations in capital cases. It provided clear guidance to lower federal courts on applying the correct standard from Schlup v. Delo.