Defense lawyers and blood evidence
Harrington v. Richter
In brief
The Court overturned the Ninth Circuit's ruling and sent Richter's case back, saying federal limits on relief for state prisoners apply even when a state court gives no reasons.
- Where it stands
- Decided
Decided 8-0 · January 19, 2011 · Opinion by Justice Kennedy
- What it’s about
- Joshua Richter asked federal courts to review his claim that his trial lawyer should have consulted blood evidence before trial.
- Who it affects
- Richter's federal challenge remains subject to the limits on relief for state prisoners, despite the state court's unexplained order.
Summary: written with AI from the case record.
What it's about
The Supreme Court did not decide whether the lawyer was ineffective; it ruled that federal limits on relief for state prisoners apply even when a state court gives no reasons, wiped out the Ninth Circuit’s ruling, and sent the case back (reversed and remanded).
The case concerns how federal courts review state-court decisions when the state court gives no explanation.
Question presented
Is a defense lawyer deficient for failing to consult blood evidence when planning strategy for trial?
What the Court decided
Holding
1. Section 2254(d) applies to Richter’s petition, even though the state court’s order was unaccompanied by an opinion explaining the court’s reasoning. 578 F. 3d 944, reversed and remanded.
- Result
- Reversed
The vote
What's next
The case returns to the Ninth Circuit for further proceedings under the federal limits the Supreme Court said apply.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Audio Recording added: Oral Arguments - Harrington
Opinion added: Harrington
More questions
- What did Justice Ginsburg say about the lawyer's failure to consult blood experts?
- She agreed that the lawyer failed to provide the representation the Constitution guarantees, but said Richter's supporting evidence did not weaken the prosecution's case enough to make the trial unfair and unreliable.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.