Yara Chum v. Patricia Anne Coyne-Fague, Director, Rhode Island Department of Corrections
HabeasCorpus Securities JusticiabilityDoctri
Did the Court of Appeals for the First Circuit err in holding that a state court decision was not contrary to federal law when, in deciding a Sixth Amendment ineffective assistance of counsel claim, the state court cited the Strickland v. Washington prejudice standard, but applied a different state law standard, failed to link that state law standard with the Strickland prejudice standard, and never resolved, as required by Strickland, whether there was a reasonable probability that, but for trial counsel's constitutionally deficient representation—as conceded by the state—the outcome of the proceeding would have been different?
QUESTION PRESENTED Did the Court of Appeals for the First Circuit err in holding that a state court decision was not contrary to federal law when, in deciding a Sixth Amendment ineffective assistance of counsel claim, the state court cited the Strickland v. Washington prejudice standard, but applied a different state law standard, failed to link that state law standard with the Strickland prejudice standard, and never resolved, as required by Strickland, whether there was a reasonable probability that, but for trial counsel’s constitutionally deficient representation—as conceded by the state—the outcome of the proceeding would have been different? i