Whether a state court's unexplained denial of a postconviction relief application can be presumed to lack adequate and independent state grounds when federal law may have influenced the decision

(CAPITAL CASE) Steven Nelson filed a subsequent state habeas application asserting federal law-claims. The Texas Court of Criminal Appeals (“TCCA”) denied Nelson authorization to file the application in an order stating, without explanation, that Nelson has “failed to show that he satisfies the requirements of Article 11.071 § 5.” That holding may have depended on the federal-law conclusion that the evidence supporting the claims was insufficient, or on inadequate state grounds, but there is no way to tell from the order if either was the case. This case presents the following questions: 1. If a state court does not specify the grounds of an order denying postconviction relief, and if one of the several potential grounds depends on federal law, may the Court presume that the decision was unsupported by adequate and independent state grounds? 2. Did the TCCA err in refusing to authorize a postconviction application that raised meritorious federal-law claims, and for which there was no adequate and independent state ground for denial? (i)