Todd J. Tibbs v. Randy Grounds, Warden
DueProcess HabeasCorpus
Does federal habeas law allow the application of a 'some evidence' standard in upholding state court factual determinations?
QUESTIONS PRESENTED Under AEDPA|, the level of deference to be afforded to state court fact findings is undoubtedly great, but it is not absolute and unquestioning. This federal habeas case, with its uncomplicated facts and procedural history, provides a straightforward example of an increasingly-common overextension of “AEDPA deference” to state court factual determinations. Based only on “some evidence” supporting the state court’s conclusion, and ignoring all uncontested evidence to the contrary, the federal court of appeal’s decision here stretches AEDPA’s deferential standard past its breaking point. Moreover, the court of appeal improperly applied the AEDPA standard for prejudice, denying relief because (as the panel stated) it was not left with grave doubt “about the verdict’s correctness.” The issues presented are: 1. Does federal habeas law allow the application of a “some evidence” standard in upholding state court factual determinations? 2. Is it correct to measure AEDPA prejudice based on the reviewing judges’ view of the verdict’s correctness? 1 The Antiterrorism and Effective Death Penalty Act of 1996, Pub. L. No. 104-132, 110 Stat. 1214, codified at 28 U.S.C. §§ 2241 et seq. i