Habeas Corpus: Claims previously adjudicated in State Court and Summary Denial
HARRINGTON v. RICHTER Decided by the United States Supreme Court January 19, 2011
Issue : Does the writ of Habeas Corpus under 28 USC § 2254, which, as amended by the Antiterrorism and Effective Death Penalyt Act of 1996 (AEDPA) limits the availability of federal habeas relief for claims previously adjudicated on the merits in state court, apply to a petition where the State Supreme Court issued only a summary denial; and whether the defendant’s counsel was ineffective where he failed to consult with forensic blood experts or introduce expert evidence in this field
Holding : The Supreme Court held that the Defendant had no right to Habeas relief; it reasoned as follows:
By its terms §2254(d) bars relitigation of any claim “adjudicated on the merits” in state court, subject only to the exceptions in §§2254(d)(1) and (d)(2). There is no text in the statute requiring a statement of reasons.
Where a state court’s decision is unaccompanied by an explanation, the habeas petitioner’s burden still must be met by showing there was no reasonable basis for the state court to deny relief.
Under 28 U. S. C. §2254(d), the availability of federal habeas relief is limited with respect to claims previously “adjudicated on the merits” in state-court proceedings.
By its terms, §2254(d) bars relitigation of a claim “adjudicated on the merits” in state court unless, among other exceptions, the earlier state-court “decision” involved “an unreasonable application” of “clearly established Federal law, as determined by” this Court, §2254(d)(1). Nothing in its text-which refers only to a “decision” resulting “from an adjudication”-requires a statement of reasons.
Where the state-court decision has no explanation, the habeas petitioner must still show there was no reasonable basis for the state court to deny relief. There is no merit to the assertion that applying §2254(d) when state courts issue summary rulings will encourage
those courts to withhold explanations. The issuance of summary dispositions can enable state judiciaries to concentrate resources where most needed.
28 U. S. C. §2254, as amended by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The text of §2254(d) states: “An application for a writ of habeas corpus on behalf of a person in custody pursuant to the judgment of a State court shall not be granted with respect to any claim that was adjudicated on the merits in State
court proceedings unless the adjudication of the claim- “(1) resulted in a decision that was contrary to or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States; or “(2) resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.”
Under AEDPA, though, it is a necessary premise that the two questions are different. For purposes of §2254(d)(1), “an unreasonable application of federal law is different from an incorrect application of federal law.” Williams, supra, at 410. A state court must be granted a deference and latitude that are not in operation when the case involves review under the Strickland standard itself.
A state court’s determination that a claim lacks merit precludes federal habeas relief so long as “fairminded jurists could disagree” on the correctness of the state court’s decision. Yarborough v. Alvarado, 541 U. S. 652, 664 (2004). And as this Court has explained,
“[E]valuating whether a rule application was unreasonable requires considering the rule’s specificity. The more general the rule, the more leeway courts have in reaching outcomes in case-by-case determinations.” Ibid. “[I]t is not an unreasonable application of clearly established Federal law for a state court to decline to apply a specific legal rule that has not been squarely established by this Court.” Knowles v. Mirzayance, 556 U. S. ___, ___ (2009)
Facts : at the crime scene of a murder and attempted murder the police found spent shell casings in the bedroom and living room. In the living room the police found blood splatter near the living room couch, blood stains in the bedroom, pools of blood in the kitchen and the doorway to the bedroom. Investigators took only a few samples of blood from the crime scene.
Police later searched the Defendant’s residence and found the gun used in the shooting as testified to by a police expert.
The prosecution had blood spatter experts as well as serologists testify at trial. The defense did not offer any testimony with regard to blood spatter or serology.