Bradshaw v. Richey, 546 U.S. 74 (2005)
Primary Holding
The doctrine of transferred intent is a permissible theory for aggravated felony murder under Ohio law, and a state court's interpretation of state law binds federal courts in habeas corpus proceedings.
In the case of Bradshaw v. Richey, a man named Kenneth Richey was convicted of murder after a fire he set to harm his ex-girlfriend accidentally killed a child. The Supreme Court decided that the way Ohio law interprets "transferred intent"—which means you can be held responsible for unintended consequences of your actions—was valid in this case. This ruling helps clarify that if someone intends to harm one person but accidentally harms another, they can still be held accountable, which reinforces the idea that people should be responsible for their actions, protecting consumers from harm in similar situations. This case is relevant if someone is involved in a situation where their intended actions cause unintended harm to others.
AI-generated plain-language summary to help you understand this case
In 1987, Kenneth T. Richey was tried in Ohio for the aggravated murder of 2-year-old Cynthia Collins, who died in a fire set by Richey. The fire was intended to kill Richey's ex-girlfriend and her new boyfriend, who were in an apartment below Collins' residence. Although the intended victims escaped unharmed, the fire resulted in the tragic death of Collins. At trial, the prosecution presented evidence of Richey's intent to kill the adults but did not establish specific intent to kill the child. Richey did not contest the forensic evidence indicating that the fire was deliberately set, as his own arson expert had concluded that the State's evidence confirmed arson. Richey was ultimately convicted of aggravated felony murder based on the theory of transferred intent and sentenced to death. Following his conviction, Richey sought postconviction relief in state court, which was denied by the trial court without an evidentiary hearing. The state appellate court affirmed this decision. Richey then pursued federal habeas relief, where the District Court allowed for some discovery but denied all of his claims. The Sixth Circuit Court of Appeals later reversed the District Court's decision, granting Richey habeas relief on two grounds: first, that the doctrine of transferred intent was not applicable under Ohio law for aggravated felony murder, and second, that Richey's trial counsel had provided ineffective assistance by mishandling the arson expert and inadequately addressing the State's expert testimony. The case reached the Supreme Court of the United States after the State of Ohio filed a petition for writ of certiorari. The Supreme Court ultimately vacated the judgment of the Sixth Circuit, indicating that the lower court had erred in its interpretation of Ohio law regarding transferred intent in aggravated felony murder cases. The Ohio Supreme Court had previously clarified that the doctrine of transferred intent was indeed applicable, asserting that Richey's culpability remained intact despite the fact that the intended victims were not harmed.
Whether the doctrine of transferred intent is a permissible theory for aggravated felony murder under Ohio law.
The judgment of the Sixth Circuit is vacated, and the case is remanded for further proceedings consistent with this opinion.
- Court
- Supreme Court
- Decision Date
- November 28, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
Rompilla v. Beard, 545 U.S. 374 (2005)
Consumer LostEven when a capital defendant's family members and the defendant himself suggest that no mitigating evidence is available, defense counsel is required by the Sixth Amendment to make reasonable efforts to obtain and review material that the prosecution will likely use as evidence of aggravation during the sentencing phase of trial.
Bell v. Cone, 543 U.S. 447 (2005)
Consumer LostThe Supreme Court held that the "especially heinous, atrocious, or cruel" aggravating circumstance used in sentencing was not unconstitutionally vague, and thus the state court's findings were entitled to deference under 28 U.S.C. § 2254(d).
Bradshaw v. Stumpf, 545 U.S. 175 (2005)
Consumer LostA defendant's guilty plea must be knowing, voluntary, and intelligent, and a conviction may be overturned if the prosecution later adopts a theory of the case that is inconsistent with the one presented during the defendant's trial.
Brown v. Payton, 544 U.S. 133 (2005)
Consumer LostThe Supreme Court held that the Ninth Circuit's decision granting habeas relief was contrary to the limits on federal habeas review imposed by 28 U.S.C. § 2254(d), affirming that the jury instructions in the penalty phase of Payton's trial were not constitutionally deficient and did not prevent the jury from considering all relevant mitigation evidence.