Harrington v. Richter
131 S. Ct. 770
| SCOTUS | 2011Background
- Richter challenged California Supreme Court's summary denial of his state habeas petition, including ineffective assistance claims.
- Trial evidence centered on Johnson and Klein shootings; defense challenged blood pattern and blood-source in doorway.
- Defense counsel did not present forensic blood experts; prosecution later presented blood pattern and serology testimony.
- California Supreme Court denied relief in a summary order; Richter pursued federal habeas under AEDPA §2254(d).
- District Court denied; Ninth Circuit granted en banc relief reversing; Supreme Court granted certiorari.
- Court reviews whether §2254(d) applies to summary denials and whether state court's Strickland ruling was unreasonable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §2254(d) applies to summary denials | Richter contends §2254(d) applies despite summary denial | California Supreme Court's summary denial still adjudicated the claim on the merits | §2254(d) applies to summary denials |
| Whether state court's Strickland ruling was unreasonable | Richter argues California Supreme Court unreasonably applied Strickland | California court reasonably applied Strickland and denied relief | California court's Strickland ruling not unreasonable |
| Whether defense counsel's performance was deficient for not consulting blood experts | Richter's counsel failed to consult experts, violating Strickland | Counsel may reasonably forego certain investigations under Strickland's discretion | Not deficient under the deferential Strickland standard |
| Whether prejudice established under Strickland | Expert testimony could have undermined prosecution evidence and helped Richter | Evidence already pointed to Richter's guilt; prejudice not established | Prejudice not established; no reasonable probability of a different outcome |
| What level of deference AEDPA requires in Strickland claims | State court misapplied Strickland; deference inappropriately minimal | AEDPA requires deference; state court's decision could be reasonable | State court's determinations not unreasonable under AEDPA |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes deficient performance and prejudice standards for ineffective assistance)
- Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (unreasonable application requires more than mere error; specific rule application)
- Yarborough v. Alvarado, 541 U.S. 652 (U.S. 2004) (fairminded jurists could disagree on state court's decision)
- Knowles v. Mirzayance, 556 U.S. 111 (U.S. 2009) (scope of AEDPA deference in Strickland cases)
- Lockyer v. Andrade, 538 U.S. 63 (U.S. 2003) (unreasonable application requires more than possible disagreement)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for reviewing sufficiency of evidence)
- Felker v. Turpin, 518 U.S. 651 (U.S. 1996) (AEDPA modified res judicata and habeas framework)
- Renico v. Lett, 559 U.S. 766 (U.S. 2010) (AEDPA precedents and deference to state courts)
- Cone v. Bell, 535 U.S. 685 (U.S. 2002) (reasonableness of reasoned state-court decisions under AEDPA)
- Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (Strickland’s prejudice standard applied with deference under AEDPA)
- Gentry v. Yarborough, 540 U.S. 1 (U.S. 2003) (presumption of reasonable strategy and deference to trial counsel)
- McMann v. Richardson, 397 U.S. 759 (U.S. 1970) (counsel performance standards and reasonable assistive conduct)
- Evans v. Chavis, 546 U.S. 189 (U.S. 2006) (limits of state habeas practices and AEDPA context)
- Jackson v. Reed, 489 U.S. 255 (U.S. 1989) (merits-preservation and presumption of adjudication on the merits)