Woods v. Donald, 575 U.S. 312, 135 S.Ct. 1372 (Mar. 30, 2015)

In this habeas corpus case, the Court reversed the Sixth Circuit, which had held that defense counsel provided per se ineffective assistance of counsel under United States v. Cronic, 466 U. S. 648 (1984), when he was briefly absent during testimony concerning other defendants. The Court determined that none of its decisions clearly establish that the defendant is entitled to relief under Cronic. The Court clarified: “We have never addressed whether the rule announced in Cronic applies to testimony regarding codefendants’ actions.” The Court was however careful to note that it expressed no view on the merits of the underlying Sixth Amendment principle.