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Name: Johnson v. Williams
Case #: 11-465
Court: US Supreme Court
District USSup
Opinion Date: 02/20/2013
Subsequent History: 133 S.Ct. 1088; 185 L.Ed.2d 105

A claim has been “adjudicated on the merits” in the state court and is subject to deferential review under AEDPA when the state court issues an opinion that addresses some of the defendant’s issues, but not the federal claim. Defendant was convicted of felony murder based on a killing during a robbery in 1993. On appeal in the state court, defendant raised a Sixth Amendment claim based on the trial court’s removal of a juror. After losing in the state courts on direct appeal and habeas proceedings, she filed for relief in federal court. The district court applied AEDPA’s deferential review standard and denied relief. The Ninth Circuit determined the state Court of Appeal overlooked or disregarded defendant’s federal claim, applied de novo review, and reversed. On the warden’s application, certiorari was granted. Held: Reversed. When a federal claim has been presented to a state court and relief is denied, it is presumed the state court adjudicated the federal claim on the merits in the absence of indication to the contrary. This presumption arises even when the opinion rejects a federal claim without expressly addressing it, while discussing other claims. The presumption applies in this case and was not rebutted by either the state court opinion or the defendant’s arguments in state court.