Background
George Steen was convicted of sexual offenses against a foster child in his care. He sought federal habeas relief, arguing his trial counsel was ineffective for failing to uncover records showing the child had other sources of sexual knowledge and a history of lying. The state trial court denied relief on both prongs of the Strickland test, while the state Court of Appeals affirmed solely on the prejudice prong, assuming deficient performance.
The court’s reasoning
The Fourth Circuit held that the district court erred by deferring to the state trial court’s analysis of deficient performance. Under the Antiterrorism and Effective Death Penalty Act, federal courts must defer to the last state court decision that adjudicates the claim on the merits with reasoned explanation. Since the state appellate court provided a reasoned decision on the prejudice prong but remained silent on deficient performance, the federal court could only defer to the prejudice analysis. The appellate court found that the undiscovered records would have been cumulative given the evidence already presented at trial. The Fourth Circuit concluded that fair-minded jurists could disagree on whether this evidence created a reasonable probability of a different verdict, so the state court’s decision was not an unreasonable application of federal law.
The appellate decision finding no prejudice is the controlling reasoned decision on the merits and is the only decision entitled to deference.
Opinion at 2
What it means going forward
This ruling reinforces that federal habeas courts cannot piece together deference from multiple state court levels when the highest court to issue a reasoned opinion addressed only part of a claim. It ensures that unaddressed elements of a claim are reviewed de novo rather than receiving deference from lower state court rulings.