Cameron Paul Crockett v. Harold W. Clarke, Director, Virginia Department of Corrections
DueProcess HabeasCorpus JusticiabilityDoctri
Does AEDPA's 'unreasonable determination of the facts' clause contemplate that materially inadequate state court fact-finding processes can satisfy § 2254 (d)(2), or did the statute silently overrule decades of this Court's precedents requiring that the state's habeas proceedings be full and fair?
QUESTION PRESENTED : Under AEDPA, state prisoners seeking federal habeas relief must demonstrate that the relevant state court’s decision involved either an unreasonable application of federal law, 28 U.S.C. § 2254(d)(1), or an unreasonable determination of the facts in light of the evidence presented in the state court proceeding, 28 U.S.C. § 2254(d)(2). This case turns on the latter pathway to relief. Since AEDPA’s enactment, the circuits have toiled with the question of the extent to which the adequacy of the state court’s fact-finding process bears on the reasonableness of its ultimate factual determination under (d)(2). No clear . consensus has emerged from the cases that have endeavored to answer this -question—only inconsistency from circuit to circuit and panel to panel. After now 26 years of AEDPA rule, the time has come for this Court to definitively settle the matter. The question presented here is as follows: Does AEDPA’s “unreasonable determination of the facts” clause contemplate that materially inadequate state court fact-finding processes can satisfy § 2254 (d)(2), or did the statute silently overrule decades of this Court’s precedents requiring that the state’s habeas proceedings be full and fair? And as it pertains to the prejudice prong of the petitioner’s ineffective assistance of counsel claim, which Crockett based principally on the compelling and unrefuted affidavits of three independent experts, did the Fourth Circuit err when it upheld the state and | district courts’ denial of habeas relief—decisions themselves premised on the supposed inconclusiveness of those expert affidavits—when no court to date has held even so much as an evidentiary hearing to allow for full factual development of the claim in the first place?