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Docket No.: 12-794
Certiorari Granted: Jun 27 2013
Argued: December 11, 2013


AEDPA, Fifth Amendment, Miranda, capital murder, death penalty, habeas, murder, self-incrimination, sentencing guidelines

PartyNames: Randy White, Warden v. Robert Keith Woodall
Petitioner: Randy White, Warden
Respondent: Robert Keith Woodall

Court Below: United States Court of Appeals for the Sixth Circuit
Citation: 685 F.3d 574
Supreme Court Docket

Randy White, Warden
Robert Keith Woodall

Robert Keith Woodall, amidst overwhelming evidence of his guilt, pled guilty to kidnapping, raping, and murdering a 16-year-old child, and thus pled guilty to all aggravating circumstances. At the penalty phase trial, the prosecutor elected to present evidence of guilt and the circumstances of the crimes. Woodall did not testify; and his request that the jury be instructed not to draw any adverse inference from his decision not to testify (a "no adverse inference instruction") was denied. He was sentenced to death by a Kentucky jury. The Kentucky Supreme Court affirmed. Even though this Court has never held that a defendant is entitled to a no adverse inference instruction at the sentencing phase of a trial where the defendant has pled guilty to the offense and all aggravating circumstances, the Sixth Circuit granted habeas relief to Woodall on the ground that the trial court's failure to provide such an instruction violated his Fifth Amendment right against self-incrimination.

Question Presented:

1. Whether the Sixth Circuit, violated 28 U.S.C. ยง2254(d)(1) by granting habeas relief on the trial court's failure to provide a no adverse inference instruction even though this Court has not "clearly established" that such an instruction is required in a capital penalty phase when a non-testifying defendant has pled guilty to the crimes and aggravating circumstances. 2. Whether the Sixth Circuit violated the harmless error standard in Brecht v. Abrahamson, 507 U.S. 619 (1993), in ruling that the absence of a no adverse inference instruction was not harmless in spite of overwhelming evidence of guilt and in the face of a guilty plea to the crimes and aggravators.


December 11, 2013

Listen to Oral Argument in WHITE v. WOODALL

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Case Documents

1WHITE v. WOODALL Oral Argument Transcript (PDF)
2WHITE v. WOODALL Oral Argument Audio