Cash v. Maxwell, 565 U.S. 1138

Maxwell was convicted in 1984 of two counts of first‑degree murder and a related robbery, in a case involving the Skid Row Stabber killings.
Sidney Storch, a jailhouse informant, testified that Maxwell confessed; multiple witnesses and palm print evidence supported Maxwell’s guilt.
The California Superior Court conducted a two‑year evidentiary hearing and concluded Storch did not lie, denying Maxwell’s habeas petition.
Maxwell pursued habeas petitions in California, then in federal court under 28 U.S.C. § 2254, with the Ninth Circuit reversing the district court.
The Ninth Circuit held that the state court’s factual finding was unreasonable under § 2254(d)(2) based on extensive evidence that Storch lied.
The Supreme Court denied certiorari, with Justice Sotomayor concurring in denial and emphasizing deference under AEDPA while noting the state court proceedings were highly fact‑bound.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Ninth Circuit reasonably found an unreasonable factual determination under §2254(d)(2).	Maxwell argues Storch lied; Ninth Circuit overstated unreasonableness.	State court findings were reasonable; deference under AEDPA applies.	Ninth Circuit determination was reasonable; certiorari denied.
Whether undisclosed impeachment evidence about Storch was material under Brady.	Undisclosed evidence could have undermined Storch’s credibility and Maxwell’s guilt.	Evidence was not material; other substantial evidence supported guilt.	State court's Brady ruling not shown to be unreasonable; certiorari denied.

Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2011) (purpose of certiorari is to clarify the law)
Harrington v. Richter, 562 U.S. 86 (2011) (unreasonable determinations of the facts under §2254(d)(2))
Napue v. Illinois, 360 U.S. 264 (1959) (due process limits on use of false evidence)
Cullen v. Pinholster, 563 U.S. 170 (2011) (AEDPA deference and review of state court decisions)
Renico v. Lett, 559 U.S. 766 (2010) (do not second-guess reasonable state court decisions)
Rice v. Collins, 546 U.S. 333 (2006) (reinstating conviction under deferential review)
Knowles v. Mirzayance, 556 U.S. 111 (2009) (reinstating state conviction under deferential standards)
Kane v. Garcia Espitia, 546 U.S. 9 (2005) (per curiam reinstatement of burglary/related convictions)
Yarborough v. Gently, 540 U.S. 1 (2003) (per curiam reinstatement of conviction in certain contexts)
Woodford v. Visciotti, 537 U.S. 19 (2002) (per curiam reinstatement of state conviction)