In a 6-3 decision, the US Supreme Court ruled Thursday that a state prisoner must comply with judicial precedent and federal law to receive habeas relief in Brown v. Davenport. The decision affects the standard use of federal courts in deciding whether constitutional errors by state trial courts are harmless. Petitioner Mike Brown argued that the US Court of Appeals for the Sixth Circuit erred in granting habeas relief. Brown argued that the state failed to meet its burden of proof in Brecht v. Abrahamson and the Effective Death Penalty and Terrorism Act of 1996 (AEDPA). In the 1993 Brecht case, the US Supreme Court said that the test for granting a writ of habeas must be whether the defendant was actually harmed by a state court error. In 1996, Congress passed the AEDPA which blocked federal habeas relief from a state court claim unless the state court ruling was contrary to clearly established federal law or applied unreasonably. After hearing the case, the majority held that a state prisoner must meet both the Brecht test and the AEDPA requirements to receive a habeas grant. In the majority opinion written by Judge Gorsuch, the court held: “When a state court has ruled on the merits of a state prisoner’s claim, a federal court may not grant a writ of habeas without applying both the evidence that the state prisoner Court outlined in Brecht as that of Congress. prescribed in AEDPA; the Sixth Circuit erred in granting Mr. Davenport habeas based solely on his assessment that he could meet the Brecht standard.” Judge Kagan along with Judge Breyer and Judge Sotomayor dissented. Kagan described the majority decision as an unnecessary barrier to the habeas courts and the parties before them. According to Kagan, there is no reason to require both tests to be met when only Brecht’s test matters.