WILLIAMS v. TAYLOR

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Case Basics
Docket No. 
99-6615
Petitioner 
Williams
Respondent 
Taylor
Advocates
(Richmond, Virginia, argued the cause for the respondent)
(Argued the cause for the petitioner)
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Facts of the Case 

Michael Wayne Williams was sentenced to death after he was convicted of two capital murders. Ultimately, Williams sought federal habeas relief, in which he requested an evidentiary hearing on three constitutional claims, regarding the fairness of his trial, which he had tried unsuccessfully to develop in the state-court proceedings. The District Court granted Williams' evidentiary hearing. However, before any hearing could be held, the Court of Appeals granted the Commonwealth's requests for an emergency stay and for a writ of mandamus and prohibition. The Commonwealth argued that Williams' evidentiary hearing was prohibited by federal law as amended by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). On remand, the District Court dismissed Williams' petition citing the AEDPA statute and finding that Williams failed to show "actual innocence." In affirming, the Court of Appeals found that Williams could not satisfy the statute's conditions for excusing his failure to develop the facts of his claims and barred him from receiving an evidentiary hearing.

Question 

Does federal law, as amended by the Antiterrorism and Effective Death Penalty Act of 1996, bar an evidentiary hearing, if the petitioner has failed to develop the factual basis of his claims in State court proceedings despite diligent efforts?

Conclusion 
Decision: 9 votes for Williams, 0 vote(s) against
Legal provision: 28 USC 2241-2255 (habeas corpus)

No. In a unanimous opinion delivered by Justice Anthony M. Kennedy, the Court held that under federal law, as amended by the AEDPA, "a 'failure to develop' a claim's factual basis in state court proceedings is not established unless there is lack of diligence, or some greater fault, attributable to the prisoner or his counsel." Justice Kennedy wrote for the Court that "comity is not served by saying a prisoner 'has failed to develop the factual basis of a claim' where he was unable to develop his claim in state court despite diligent effort. In that circumstance, an evidentiary hearing is not barred."

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WILLIAMS v. TAYLOR. The Oyez Project at IIT Chicago-Kent College of Law. 13 December 2014. <http://www.oyez.org/cases/1990-1999/1999/1999_99_6615>.
WILLIAMS v. TAYLOR, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1990-1999/1999/1999_99_6615 (last visited December 13, 2014).
"WILLIAMS v. TAYLOR," The Oyez Project at IIT Chicago-Kent College of Law, accessed December 13, 2014, http://www.oyez.org/cases/1990-1999/1999/1999_99_6615.