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Keywords

appealtrialtestimonyhabeas corpus
habeas corpus

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Johnson v. Norris, 537 F.3d 840

Facts

Stacey Eugene Johnson was convicted of the murder of Carol Heath and sentenced to death in 1994. After a series of appeals and retrials, including a reversal by the Supreme Court of Arkansas, Johnson was retried and again convicted. Key evidence included testimony from Heath's daughter, Ashley, who identified Johnson as the intruder, and DNA evidence linking Johnson to the crime scene. Johnson's attempts to access Ashley's psychotherapy records and to challenge the exclusion of certain testimony were denied by the trial court.

Stacey Eugene Johnson was convicted of the murder of Carol Heath and sentenced to death in 1994. The Supreme Court of Arkansas reversed the conviction, see Johnson v. Arkansas, 326 Ark. 430, 934 S.W.2d 179 (Ark.1996) ('Johnson I'), and the case was retried. Johnson was again convicted and sentenced to death, and a divided Supreme Court of Arkansas affirmed.

Issue

The main legal issues included whether the trial court's denial of access to a juvenile witness's psychotherapist records violated Johnson's constitutional rights, whether there was a Brady violation, and whether Johnson's counsel was ineffective.

Johnson first argues that his rights under the Sixth and Fourteenth Amendments were violated when the district court denied Johnson access to Ashley's psychotherapist records.

Rule

The court applied the standard that a federal court shall not grant a writ of habeas corpus on a claim adjudicated on the merits by a state court unless the state court's decision was contrary to or involved an unreasonable application of clearly established federal law.

A federal court shall not grant a writ of habeas corpus on a claim that was adjudicated on the merits by a state court unless the state court's decision 'was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court,' or the state court's decision 'was based on an unreasonable determination of the facts in light of the evidence presented in the State court.' 28 U.S.C. § 2254(d).

Analysis

The court found that the trial court's denial of access to Ashley's psychotherapy records did not violate Johnson's rights, as the privilege was deemed more important than the need for evidence. The court also ruled that there was no Brady violation since the state did not have access to the records, and Johnson failed to demonstrate ineffective assistance of counsel under the Strickland standard.

The Arkansas courts rejected this argument, reasoning that the denial of access did not violate Johnson's Sixth and Fourteenth Amendment rights, because according to Jaffee v. Redmond, 518 U.S. 1, 116 S.Ct. 1923, 135 L.Ed.2d 337 (1996), the psychotherapist 'privilege is more important than 'the need for probative evidence.' Johnson II, 27 S.W.3d at 412 (quoting Jaffee, 518 U.S. at 9-10, 116 S.Ct. 1923).

Conclusion

The Court of Appeals affirmed the district court's denial of Johnson's habeas corpus petition, concluding that the state court's decisions were reasonable and did not violate federal law.

We reach the same conclusion with respect to Johnson's claim. Although Davis and Ritchie establish that in at least some circumstances, an accused's constitutional rights are paramount to a State's interest in protecting confidential information, those decisions do not establish a specific legal rule that answers whether a State's psychotherapist-patient privilege must yield to an accused's desire to use confidential information in defense of a criminal case.

Who won?

The prevailing party was the state, as the court upheld the denial of Johnson's habeas corpus petition, finding that the state court's rulings were not unreasonable.

The prevailing party was the state, as the court upheld the denial of Johnson's habeas corpus petition, finding that the state court's rulings were not unreasonable.

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