FourthAmendment HabeasCorpus CriminalProcedure Punishment Securities Privacy
Does a district court abuse its discretion when it denies a habeas petitioner an evidentiary hearing where the state record remains undeveloped, where the petitioner bears no fault for the failure to develop the record, and where the petitioner states a colorable claim for relief based on the totality of the record?
This case arises from a habeas petition brought under 28 U.S.C. § 2254 alleging ineffective assistance of counsel . The claim arose because d efense counsel failed to argue that inculpatory statements made to law enforcement should be suppressed as the product of an illegal arrest. In state court, Mr. Young waited nearly six years for a response before filing a mandamus petition , which prompted the State to finally respond. That same day, t he state postconviction court denied Mr. Young ’s motion without affording him a hearing. It never found that the arrest was supported by probable cause ; instead, it adopted the State’s contention that the issue wa s litigated in the trial and on direct appeal . The state appellate court affirmed that ruli ng without a written opinion. The federal habeas court rejected the State’s argument that the issue was previously raised , and so it conducted de novo review of the claim. Nevertheless, it denied Mr. Young habeas relief , finding for the first time that the arrest was supported by probable cause . It only considered the transcript from an unrelated suppression hearing, even though the trial testimony of the lead detective showed a lack of probable cause. And it denied Mr. Young’s request for an evidentiary hearing to develop the fact ual basis for the claim. The Eleventh Circuit affirmed . This petition presents the following question for review: 1. Does a district court abuse its discretion when it denies a habeas ii petitioner an evidentiary hearing where the state record remains undeveloped , where the petitioner bears no fault for the failure to develop the record, and where the petitioner states a colorable claim for relief based on the totality of the record ?