Williams v. Taylor

Summary

Justice Kennedy delivered the unanimous opinion holding that 28 U.S.C. § 2254(e)(2) restricts federal evidentiary hearings only when the prisoner or counsel lacked diligence, or bore greater fault, in developing the claim’s factual basis in state court. The Court affirmed the denial of a hearing on Williams’s claim concerning an undisclosed psychiatric report because state habeas counsel inadequately investigated known references to the report and Williams conceded he could not satisfy the statute’s additional requirements. It reversed as to the juror-bias and prosecutorial-misconduct claims because counsel had reasonably pursued investigation and had no reason to discover the relationships concealed during voir dire. The Court remanded for further proceedings, leaving the applicable prejudice standard for the lower courts. There were no separate opinions.