Keith Edmund Gavin v. John Q. Hamm, Commissioner, Alabama Department of Corrections
DueProcess HabeasCorpus Punishment Securities
Whether AEDPA deference applies to state-court reasoning not articulated in the decision
QUESTIONS PRESENTED The Antiterrorism and Effective Death Penalty Act of 1996 (““AEDPA”) provides that habeas relief “shall not be granted with respect to any claim that was adjudicated on the merits” in state court unless, as relevant here, the state-court decision “was contrary to, or involved an unreasonable application of, clearly established Federal law.” 28 U.S.C. § 2254(d)(1). This petition presents three questions relating to whether and when AEDPA deference applies to a state-court decision: 1. Whether federal habeas courts must defer to reasoning that appears nowhere in a state-court decision. 2. Whether federal habeas courts evaluating a claim for ineffective assistance of counsel must defer to a state-court decision that applies a demonstrably incorrect standard of proof for prejudice under Strickland v. Washington, 466 U.S. 668 (1984). 3. Whether federal habeas courts must defer to a state-court’s resolution of a claim that rested exclusively on the application of a state-law evidentiary rule and did not resolve a habeas petitioner’s federal constitutional claim “on the merits.” i