Wood v. Allen

Summary

The Supreme Court affirmed the Eleventh Circuit's reinstatement of the denial of federal habeas relief, holding that even assuming, as petitioner urged, that the state court's factual findings are reviewed solely under 28 U.S.C. § 2254(d)(2), the Alabama court's determination that Wood's trial counsel made a strategic decision not to pursue or present evidence of his borderline mental retardation was not an unreasonable determination of the facts. Because the determination was reasonable under that standard, the Court found it unnecessary to resolve the relationship between §§ 2254(d)(2) and (e)(1), and it declined to reach Wood's argument that the state court unreasonably applied Strickland under § 2254(d)(1) because that question was not fairly included in the questions presented. Justice Stevens, joined by Justice Kennedy, dissented, contending that the record showed inattention and neglect rather than a strategic choice and that the state court's finding was therefore unreasonable under § 2254(d)(2).