Michael Williams v. Taylor

Supreme Court of the United States · 2000 · Federal Courts

Federal CourtsHabeas CorpusAEDPAEvidentiary Hearings28 U.S.C. § 2254(e)(2)AEDPAfederal habeasevidentiary hearing

Facts

Williams filed a federal habeas petition seeking evidentiary hearings on claims that had not been factually developed in Virginia state court, including an alleged Brady violation involving a psychiatric report on witness Cruse, juror bias by juror Bonnie Stinnett, and prosecutorial misconduct based on prosecutor Woodson's silence about Stinnett's connections. The psychiatric report's existence and contents were referenced in a sentencing transcript that Williams's state habeas counsel possessed, but counsel made only limited efforts to pursue it. By contrast, the trial record gave no reason to suspect that Stinnett had failed to disclose that she had been married to prosecution witness Deputy Sheriff Meinhard or that Woodson had represented her in the divorce. State habeas counsel sought investigative assistance regarding possible jury irregularities, but the Virginia Supreme Court denied the request and dismissed the petition before the facts about Stinnett and Woodson were uncovered.

Issue

Does 28 U.S.C. § 2254(e)(2) bar a federal evidentiary hearing whenever the factual basis of a habeas claim was not developed in state court, or only when the prisoner failed to develop the facts through lack of diligence or other fault? Applying that standard, did Williams fail to develop the factual bases of his Brady, juror bias, and prosecutorial misconduct claims in state court?

Rule

Under § 2254(e)(2), a prisoner has not 'failed to develop the factual basis of a claim in State court proceedings' unless the lack of development is attributable to the prisoner's or counsel's lack of diligence, or greater fault. Diligence depends on whether the prisoner made a reasonable attempt, in light of the information available at the time, to investigate and pursue the claim in state court; in the usual case, this requires at least seeking an evidentiary hearing in state court in the manner prescribed by state law.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a federal habeas petition challenging a murder conviction from Ohio, Daniel Ortiz seeks an evidentiary hearing on a claim that the prosecution withheld a laboratory memo impeaching its key witness. During state postconviction proceedings, Ortiz's lawyer had a trial transcript in which the prosecutor and trial judge discussed a "supplemental lab memorandum" concerning that witness, but counsel sent only one general discovery letter and never pursued the specific memo or requested a state evidentiary hearing.

Is Ortiz barred by § 2254(e)(2) from obtaining a federal evidentiary hearing unless he satisfies that statute's additional stringent requirements?

Explanation. Yes. The majority held that § 2254(e)(2) is fault-based: a prisoner has not "failed to develop" the facts unless the lack of development is attributable to lack of diligence or greater fault by the prisoner or counsel. Diligence requires a reasonable attempt, in light of the information available at the time, to investigate and pursue the claim in state court. Where counsel had clear notice from the record that specific potentially material evidence existed, a mere general request followed by no meaningful follow-up is only cursory effort, so § 2254(e)(2)'s opening clause is triggered.