6th Cir.

DAVID LEE SANDERS v. LAURA PLAPPERT, Warden UNITED STATES OF AMERICA

March 3, 2026 ·16-6152 ·Published ·Julia Smith Gibbons · By James Taylor

The Sixth Circuit upheld the constitutionality of AEDPA and affirmed the denial of Sanders's habeas petition. The court found no merit in Sanders's claims regarding jury instructions and ineffective assistance of counsel.

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Background

David Lee Sanders was sentenced to death for the murder and robbery of two men in 1987. His defense of insanity was rejected by the jury. Sanders challenged the constitutionality of AEDPA and claimed ineffective assistance of counsel.

The court’s reasoning

The court held that AEDPA is constitutional and that Sanders’s claims did not meet the standard for habeas relief. The jury instructions were not found to be confusing, and the ineffective assistance of counsel claims did not demonstrate prejudice.

We hold that AEDPA is constitutional and, applying it to Sanders’s claims, the Kentucky Supreme Court’s decisions on jury instructions and several of Sanders’s ineffective assistance of counsel claims were not contrary to law and did not involve an unreasonable application of federal law.

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The dissent

What it means going forward

The decision affirms the denial of Sanders’s habeas petition and upholds his death sentence.

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