JAMES SCOTT V. RON BROOMFIELD
Split Score
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Case Summary
Disposition
Reversed
The Ninth Circuit reversed the district court’s grant of habeas relief to death-row inmate James Robert Scott, holding that the California Supreme Court reasonably rejected Scott’s numerous ineffective-assistance-of-counsel claims under the deferential standards of AEDPA and Strickland v. Washington. The panel found no individual or cumulative prejudice from trial counsel’s alleged errors, reinstating Scott’s murder conviction and death sentence and remanding for consideration of remaining claims.
Circuit Split Identified
Legal Issue
Whether federal habeas courts may grant relief on an ineffective-assistance-of-counsel claim based on the cumulative prejudice of multiple alleged attorney errors when no single error is independently prejudicial under Strickland and AEDPA.
Circuit Positions
Cumulative prejudice from multiple non-prejudicial attorney errors can warrant habeas relief on an IAC claim; state courts must consider errors in the aggregate.
Supreme Court has not clearly established a cumulative-prejudice doctrine for IAC habeas claims; therefore, cumulative prejudice cannot justify federal habeas relief.
Conflict Summary
The Ninth Circuit and some earlier cases recognize that federal courts must aggregate the prejudicial effect of counsel’s multiple errors ("cumulative prejudice") when assessing ineffective-assistance claims on habeas review, whereas the Sixth, Eighth, Fifth, and Eleventh Circuits conclude that Supreme Court precedent has not clearly established such a cumulative-error doctrine for Sixth Amendment claims, so state courts cannot be reversed on that basis.