Stewart v. Smith

Summary

The Court held that Arizona Rule of Criminal Procedure 32.2(a)(3) does not require a court to consider the merits of a claim to determine whether it is of sufficient constitutional magnitude, making the state‑court waiver determination independent of federal law. Accordingly, the Ninth Circuit’s ruling that the state court’s decision barred federal habeas review was erroneous, the Court reversed that judgment, and the case was remanded for further proceedings.