Michael Stephen Combs was convicted of first-degree murder and sentenced to death in California state court for the 1990 killing of Janine Lee. After his conviction and sentence were affirmed on direct appeal, Combs filed a federal habeas corpus petition under 28 U.S.C. § 2254. The California Supreme Court summarily denied his claims without providing written reasoning. The district court denied the petition but granted a certificate of appealability on Combs' claims of ineffective assistance of counsel during the penalty phase. Combs appealed, arguing that his trial counsel was ineffective for failing to investigate his biological family, prepare expert witnesses, and present mitigating evidence, and he requested the appellate court expand the certificate of appealability to cover additional claims regarding his competency and juror bias.
The panel applied the deferential standard of the Antiterrorism and Effective Death Penalty Act (AEDPA) to the California Supreme Court's silent denial. Because the state court provided no reasoning, the Ninth Circuit independently reviewed the record to determine if any reasonable argument supported the denial. The court addressed Combs' overarching claim that the state court applied an improper 'compelling connection' standard for ineffective assistance of counsel. The panel rejected this, holding that it is reasonable to conclude the state court applied the correct Strickland prejudice standard, which requires a reasonable probability that the outcome would have been different. The court then analyzed twelve specific subclaims of ineffective assistance. It found that trial counsel conducted a reasonable investigation into Combs' biological family and social history, and their strategic decision to focus on evidence available at the time did not fall below an objective standard of reasonableness. Regarding expert witnesses, the court found counsel provided adequate preparation and that the experts' differing diagnoses did not constitute prejudice given the overwhelming aggravating evidence. The panel also rejected claims regarding the failure to rebut arguments about remorse, the failure to present a substance abuse expert, and the dissemination of a court-appointed expert's report, noting that counsel's strategic decisions were reasonable and that the evidence was not clearly mitigating. Finally, the court denied a certificate of appealability for Combs' competency and juror bias claims, finding the state court's summary denial was not unreasonable because the record did not raise a bona fide doubt regarding Combs' competency and the juror misconduct claim relied on inadmissible hearsay.
The decision affirms Combs' death sentence and the denial of federal habeas relief. The ruling clarifies that when a state court summarily denies a habeas petition, the federal court must identify any reasonable argument that could support the denial, even if the state court did not articulate it. It reinforces the high bar for proving ineffective assistance of counsel in capital cases under AEDPA, particularly when the state court's decision can be supported by a reasonable application of the Strickland standard. The court's denial of the certificate of appealability for competency and juror bias claims limits further federal review on those specific issues.