Samuel Fields v. Laura Plappert, Warden

This Court has recognized that “[i]n the constitutional sense, trial by jury in a criminal case necessarily implies at the very least that the ‘evidence developed’ against a defendant shall come from the witness stand in a public courtroom where there is full judicial protection of the defendant’s right of confrontation, of crossexamination, and of counsel.” Turner v. Louisiana, 379 U.S. 466, 472-73 (1965). In Sam Fields’s federal habeas case, a panel of the Sixth Circuit found (in unison with the Sixth Circuit’s prior decisions) that this Court’s general rule, as stated in Turner and other cases of this Court, qualified as clearly established federal law under 28 U.S.C. § 2254(d)(1) (“AEDPA”). Accordingly, Fields was entitled to a determination of whether the state court’s decision in his case—regarding the jury’s consideration of physical evidence that did not come from the courtroom—was an unreasonable application of this general rule. But during en banc review, a majority determined that this Court “abrogated” the prior Sixth Circuit decisions by subsequently interpreting § 2254(d)(1) to exclude general or abstract rules from qualifying as clearly established Supreme Court law. The majority further concluded that the rule was not a holding of Turner or any other Supreme Court case for the purposes of AEDPA. As a result, Fields no longer was entitled to a determination of whether the state-court decision unreasonably applied this Court’s rule. This Court subsequently issued Andrew v. White, 145 S. Ct. 75, 78 (2025), in which this Court ruled that a similar circuit court decision finding that the general or abstract rule at issue there could not satisfy AEDPA’s “clearly established law” requirement was “wrong.” The Court ruled that § 2254(d)(1) does not exclude abstract or general principles from qualifying as clearly established law, and when this Court relies on a legal rule or principle to decide a case, that principle is a holding of this Court for purposes of AEDPA. This Court remanded the case to the circuit court for a determination of whether the state-court decision unreasonably applied this Court’s general rule. Less than 30 days after this Court decided Andrew, Fields requested the Sixth Circuit to recall its mandate on the ground that Andrew created an exceptional circumstance warranting the recall. In a divided decision, the Sixth Circuit denied the motion. This case thus presents the following questions: May a subsequent decision of this Court calling into question the correctness and integrity of a circuit court’s judgment qualify as an exceptional circumstance justifying a recall of the circuit court’s mandate, and if so, did the lower court err in denying the motion to recall?