Wilson v. Sellers
Wilson v. Sellers, 584 U.S. ___, is a United States Supreme Court case in which the court held that a federal court sitting in a habeas corpus proceeding should "look through" an unexplained, summary ruling to the last related state-court decision that provides a relevant rationale and presume that the unexplained decision adopted the same reasoning. The State may rebut the presumption by showing that the unexplained decision most likely relied on different grounds than the reasoned decision below.
Background
In 1997, a Georgia jury convicted Marion Wilson of murder and sentenced him to death. In December 1999, the Supreme Court of Georgia affirmed on direct appeal. Wilson next petitioned for a writ of habeas corpus in state court. The petition was denied in a written opinion by the state superior court, which was summarily affirmed by the state supreme court, and denied review by the U.S. Supreme Court.Wilson then filed another petition for habeas corpus, now in the United States District Court for the Middle District of Georgia, which was denied. In December 2014, a unanimous panel of the United States Court of Appeals for the Eleventh Circuit affirmed, also rejecting Wilson's petition. In August 2016, the full en banc Eleventh Circuit again rejected the petition by a vote of 6–5, with Circuit Judge William H. Pryor Jr. writing for the majority and Circuit Judges Adalberto Jordan and Jill A. Pryor writing dissents.