Federal review of state rulings
Wilson v. Sellers
In brief
The Supreme Court overturned the Eleventh Circuit’s judgment and returned Wilson’s case to that court for another look.
- Where it stands
- Decided
Decided 6-3 · April 17, 2018 · Opinion by Justice Breyer
- What it’s about
- The Supreme Court overturned the Eleventh Circuit’s ruling and sent Wilson’s case back to it (remanded).
- Who it affects
- The order sends Wilson’s case back to the Eleventh Circuit; it does not give the final outcome of his challenge to his imprisonment.
Summary: written with AI from the case record.
What it's about
It said a federal court reviewing a prisoner’s challenge should presume an unexplained state ruling used the reasons in the last related state decision that explained its ruling, unless the state shows it likely relied on different grounds.
The dispute arose from federal review of a state court’s unexplained rejection of Wilson’s claim.
Question presented
Did this Court's decision in Harrington v. Richter, 562 U.S. 86 (2011), silently abrogate the presumption set forth in Ylst v. Nunnemaker, 501 U.S. 797 (1991)—that a federal court sitting in habeas proceedings should "look through" a summary state court ruling to review the last reasoned decision—as a slim majority of the en banc Eleventh Circuit held in this case, despite the agreement of both parties that the Ylst presumption should continue to apply?
What the Court decided
Holding
Judgment REVERSED and case REMANDED. Breyer, J., delivered the opinion of the Court, in which Roberts, C. J., and Kennedy, Ginsburg, Sotomayor, and Kagan, JJ., joined. Gorsuch, J., filed a dissenting opinion, in which Thomas and Alito, JJ., joined.
- Result
- Reversed
The vote
What's next
The case returns to the Eleventh Circuit for further proceedings. The final outcome of Wilson’s challenge is not stated here.
Each side's argument
- Wilson
- Wilson argued that federal courts should keep using the rule that looks to the last state-court decision that explained its reasons.
- Sellers
- Sellers also agreed that the rule should continue to apply.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Opinion added: Wilson
Opinion added: opinion
Brief added: Questions Presented
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.