Supreme Court of the United States
Vincent Cullen, Acting Warden v. Scott Lynn Pinholster
April 4, 2011179 L. Ed. 2d 557
Summary
The Court held that federal review under 28 U.S.C. § 2254(d)(1) is confined to the record that was before the state court that adjudicated the claim on the merits. Applying that limitation and doubly deferential review, the Court held that Pinholster failed to show that the California Supreme Court unreasonably rejected either the deficient-performance or prejudice component of his penalty-phase ineffective-assistance claim, and it reversed the Ninth Circuit. Justice Sotomayor, dissenting, would have considered properly admitted federal-hearing evidence; Justice Breyer would have remanded for application of the announced standard; and Justice Alito agreed with the result but disputed the record-limitation holding.
Holding
- Scope of review under 28 U.S.C. § 2254(d)(1). When a state court has adjudicated a claim on the merits, federal review under § 2254(d)(1) is limited to the record that was before that state court; evidence later introduced in federal court cannot be considered in determining whether the state decision was unreasonable.
- Application of AEDPA to the state court's summary merits denial. Section 2254(d) applied because the California Supreme Court had adjudicated Pinholster's ineffective-assistance claim on the merits, even though its decisions were summary denials. Under that framework, Pinholster could prevail only by showing that there was no reasonable basis for the state court's decision.
- Penalty-phase ineffective assistance of counsel. Pinholster failed to establish that the California Supreme Court unreasonably applied the governing ineffective-assistance standard. The state court could reasonably conclude that counsel's limited mitigation presentation reflected a strategic choice and that the additional state-court evidence did not create a substantial likelihood of a different sentence.
Docket No. 09-1088