In Shelton v. Sec., Dep’t of Corrections, No. 11-13515 (Aug. 24, 2012), the Court reversed the grant of habeas relief to a Florida inmate convicted of cocaine trafficking, and sentenced to 18 years in jail.
The district court held that the Florida statute violated Due Process, because the law partially eliminated an element of mens rea – under the Florida statute, an offender must be aware of the presence of an unlawful substance but need not be aware of the substance’s unlawful nature. Reversing, the Court held that this ruling was not permitted by AEDPA, which allows a federal court to reverse a state court’s determination only if that state court determination unreasonably applies clearly established Supreme Court precedent. Here, the Supreme Court has not held that a statute with only a partial mens rea violates Due Process. The Court expressed no view on the underlying constitutional question – only that the issue was "novel" and could be the basis for habeas relief.
