White v. Woodall
United States Supreme Court
134 S. Ct. 1697 (2014)
After pleading guilty to murder, rape, and kidnapping, Woodall (defendant) declined to testify at sentencing and asked for a jury instruction that he need not testify and that no adverse inference should be drawn from his silence; the trial court refused, the Kentucky Supreme Court affirmed, and Woodall obtained federal habeas relief from the district court, affirmed by the Sixth Circuit, on the theory the refusal violated clearly established Fifth Amendment law. The Supreme Court granted certiorari.
Whether a state prisoner seeking federal habeas relief must show that the state court's ruling was an objectively unreasonable application of clearly established federal law, as opposed to merely a failure to extend existing precedent to a new context.