Do this Court's precedents prohibiting the application of arbitrary rules to exclude evidence 'clearly establish,' under § 2254(d)(1), that a state court's misapplication of a valid state rule can rise to a federal constitutional violation?

Criminal defendants are guaranteed “a meaningful opportunity to present a complete defense.” Crane v. Kentucky , 476 U.S. 683, 689 –90 (1986) . Yet the states maintain “broad latitude under the Constitution to establish rules excluding evidence from crimi-nal trials.” United States v. Scheffer , 523 U.S. 303, 308 (1998) . That latitude is curtailed only if the rules are “arbitrary or disproportionate to the purposes they are designed to serve,” Rock v. Arkansas, 483 U.S. 44, 55 – 56 (1987) , or if they “infringe[ ] upon a weighty interest of the accused,” Scheffer, 523 U.S. at 308. “Only rarely ha[s] [ this Court] held that the right to present a defense was violated by the exclusion of defense evidence under a state rule of law.” Nevada v. Jackson , 569 U.S. 505, 509 (2013) . And when, as here, the right is implicated in a 28 U.S.C. § 2254 petition, the state court’s application of this Court’s precedents must be given “substantial deference.” Jackson , 569 U.S. at 512. The questions presented are: 1. Do th is Court’s precedents prohibiting the application of arbitrary rules to exclude evidence “clearly establish,” under § 2254(d)(1) , that a state court’s misapplication of a valid state rule can rise to a federal constitutional violation? 2. Do this Court’s precedents, which generally have found that a defendant has a weighty interest in presenting “ ‘facts’ about the alleged crime at hand,” Scheffer, 523 U.S. at 316– 17 n.13, clearly establish that a defendant also has a weighty interest in presenting extrinsic credibility evidence unrelated to the facts of the underlying crime? ii PARTIES TO T HE PROCEEDING Petitioner Mike Brown was the Warden at the correctional facility where Respondent Louis Chandler was being held in custody while the case was pending in district court. RELATED CASES • People v. Chandler (After Remand) , Michigan Court of Appeals, Docket No. 329605 , Opinion issued December 19, 2017 (affirming Chandler’s convictions ). • People v. Chandler , Michigan Supreme Court, Docket No. 157202, Order issued October 2, 2018 (denying Chandler’s application for leave to appeal). • Chandler v. Kowalski , United States District Court for the Western District of Michigan, Report and Recommendation issued February 3, 2023 (V ERMAAT , M.J.) (recommending that petition for writ of habeas corpus be denied). • Chandler v. Kowalski , United States District Court for the Western District of Michigan, Order issued February 23, 2023 ( adopting the Report and Recommendation, denying petition for writ of habeas corpus , and granting a certificate of appealability ). • Chandler v. Brown , United States Court of Appeals for the Sixth Circuit, vacated Opinion issued January 24, 2025 ( reversing the district court and conditionally granting petition for a writ of habeas corpus). iii • Chandler v. Brown , United States Court of Appeals for the Sixth Circuit, Order issued May 9, 2025 (granting rehearing en banc and returning case to original panel for entry of an amended opinion). • Chandler v. Brown , United States Court of Appeals for the Sixth Circuit, Amended Opinion issued May 9, 2025 (reversing the district court and conditionally granting petition for a writ of habeas corpus). • Chandler v. Brown , United States Court of Appeals for the Sixth Circuit, Order issued July 31, 2025 (denying petition for rehearing en banc).