To what extent, if any, should a federal court defer to prior state court factfinding and adjudication under the Antiterrorism and Effective Death Penalty Act (AEDPA) in the absence of an evidentiary hearing or other appropriate opportunity to develop facts?

QUESTION PRESENTED This Court has held that “capital proceedings be policed at all stages by an especially vigilant concern for procedural fairness and for the accuracy of factfinding.” Monge v. California, 524 U.S. 721, 732 (1998). Indeed, the Court has “demanded that factfinding procedures aspire to a heightened standard of reliability.” Ford v. Wainwright, 477 U.S. 399, 411 (1986) (citing Spaziano v. Florida, 468 U.S. 447, 456 (1984)). What, then, to make of inadequate capital state-court factfinding processes under review in a § 2254 case? This presents the following question for this Court’s review: To what extent, if any, should a federal court defer to prior state court factfinding and adjudication under the Antiterrorism and Effective Death Penalty Act (AEDPA) in the absence of an evidentiary hearing or other appropriate opportunity to develop facts? 1