Because AEDPA limits the power of a federal court to grant habeas relief on a claim which has been adjudicated by a state court “on the merits,” it requires deference to a state court’s summary denial of a petitioner’s claim. In a state habeas proceeding, petitioner alleged IAC for failing to introduce forensic blood expert testimony that supported his theory of the shooting. The California Supreme Court denied the petition in a one-sentence summary denial. Petitioner then sought federal habeas relief and the Ninth Circuit granted the petition. As a preliminary matter, the high court considered the question of whether AEDPA deference applies to a state court’s summary disposition of a claim. The court held section 2254(d) applies, even though the state court’s order was unaccompanied by an opinion explaining the reasons. The language of the statute does not require a statement of reasons; it only requires a “decision” resulting from an “adjudication on the merits.” Nor is there merit to petitioner’s argument that section 2254(d) does not apply because the California Supreme Court order did not say it was adjudicating the claim “on the merits.” Absent any indication or state-law procedural principles to the contrary, there is a judicial presumption that when a federal claim is presented to the state court and that court denies relief, the court adjudicated the claim on the merits. (Cf. Harris v. Reed (1989) 489 U.S. 255, 265.) And while the presumption can be overcome if there is reason to believe another explanation for the state court’s decision is more likely, that showing has not been made here.
Under AEDPA, federal habeas relief may not be granted with respect to an IAC claim unless the state court’s decision denying relief involves “an unreasonable application” of Strickland v. Washington (1984) 466 U.S. 668. The high court reversed the Ninth Circuit’s decision granting habeas relief because that court did not give the proper deference required by AEDPA to the state court decision that petitioner received adequate representation. The high court felt the Ninth Circuit applied de novo review because it felt there was a strong case for relief. “The pivotal question is whether the state court’s application of the Strickland standard was unreasonable. This is different from asking whether defense counsel’s performance fell below Strickland’s standard. Were that the inquiry, the analysis would be no different than if, for example, this Court were adjudicating a Strickland claim on direct review.” Here, it was reasonable for the state court to have concluded that trial counsel could pursue his trial strategy without the use of an expert. And it was also reasonable for the state court to have concluded that prejudice was not proven because the expert’s declaration presented in the habeas petition showed only a theoretical possibility while there was plenty of circumstantial evidence pointing to guilt.