Brief filed: 09/05/2025
Documents
Fields v. Plappert
United States Supreme Court; Case No. 25-5286
Argument(s)
Samuel Fields, who has maintained his innocence for more than three decades, was convicted and sentenced to death for the murder of his girlfriend’s landlord because—behind the jury room’s closed doors—jurors reached their verdict based on an experiment they devised to test the prosecution’s central theory of guilt, not evidence developed at trial. This new evidence purported to confirm how Mr. Fields accessed the victim’s residence by unscrewing a storm window, but it was neither subjected to our adversarial system’s basic procedural safeguards nor the heightened standards demanded in capital cases. Consequently, on appeal, Mr. Fields challenged the jury’s consideration of extrinsic evidence as a violation of his rights to confrontation, due process, and a fair trial, as guaranteed by the Fifth, Sixth, and Fourteenth Amendments, relying on this Court’s holdings in a series of decisions that instruct: “In 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 cross-examination, and of counsel.” However, a majority of the Sixth Circuit sitting en banc reversed a panel’s conditional grant for writ of habeas corpus because it concluded that Turner and its kin are not “clearly established federal law,” thereby revealing a misunderstanding of both this Court’s precedent and the required inquiry under Section 2254 of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). For these reasons, this Court should grant review and expose the Sixth Circuit’s cramped view of habeas relief as an unwarranted curtailment of the Great Writ, even under the restrictions AEDPA places on Article III courts’ power to enforce the federal Constitution as the supreme law of the land.
Author(s)
Stephen Ross Johnson and Anne E. Passino, Ritchie, Johnson & Stovall, P.C., Knoxville, TN; Jeffrey T. Green, NACDL, Washington, DC
