Harrington v. Richter

Supreme Court of the United States · 2011 · Federal Courts

Federal CourtsHabeas CorpusAEDPAIneffective Assistance of Counsel28 U.S.C. § 2254(d)adjudicated on the meritssummary denialunreasonable application

Facts

Richter was convicted of murder and related offenses after evidence showed that stolen items and matching ammunition were found at his home and after he admitted disposing of guns connected to the crime. At trial, after defense counsel argued that the victim Klein had actually been shot in the bedroom doorway and moved, the prosecution presented late forensic testimony on blood patterns and serology. On state habeas, Richter claimed counsel was ineffective for not consulting or presenting blood experts who could have supported his theory about the source of a blood pool near the bedroom doorway. The California Supreme Court summarily denied the petition without explanation.

Issue

Does AEDPA's deferential standard in 28 U.S.C. § 2254(d) apply when a state court denies relief in an unexplained summary order? If so, did the California Supreme Court unreasonably apply Strickland in rejecting Richter's ineffective-assistance claim based on counsel's failure to consult and present forensic blood experts?

Rule

Section 2254(d) applies to claims adjudicated on the merits in state court even when the state court gives no reasons. When the state court issues an unexplained denial, the habeas petitioner must show there was no reasonable basis for the state court to deny relief, and federal courts must consider what arguments or theories supported or could have supported the state-court decision and ask whether fairminded jurists could disagree. For Strickland claims on federal habeas, review is doubly deferential: the question is not whether counsel's actions were reasonable, but whether there is any reasonable argument that counsel satisfied Strickland's deferential standard.

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In Phoenix, Diego Moreno was convicted in Arizona state court and later filed a state habeas petition alleging ineffective assistance of counsel. The Arizona Supreme Court denied relief in a one-line order stating only, "Petition denied," and Diego then sought federal habeas relief arguing the federal court should review his claim de novo because the state court gave no reasons.

How should the federal habeas court treat the state court's one-line denial?

Explanation. Section 2254(d) applies even when the state court issues an unexplained summary denial. When a federal claim was presented and relief was denied, the federal court presumes a merits adjudication absent contrary indication or state-law procedural principles to the contrary. The petitioner must show there was no reasonable basis for the state court to deny relief; the absence of reasons does not trigger de novo review.