Hittson v. Chatman, 135 S. Ct. 2126

AEDPA directs federal habeas review to defer to state-court reasoning under §2254(d).
Last-state-court reasoning governs deference when there is a reasoned opinion; unexplained orders trigger look-through presumptions.
Ylst v. Nunnemaker permits looking through an unexplained order to the last reasoned decision.
Eleventh Circuit abandoned Ylst’s look-through for Georgia Supreme Court’s unexplained denial of a certificate of probable cause.
Richter v. Harrington reaffirmed looking through unexplained dispositions; the Court cautions against inventing hypothetical grounds.
Concurrence agrees cert denial but faults Eleventh Circuit for discarding Ylst and urges proper look-through under case law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Should Ylst look-through govern unexplained state orders?	Hittson: Ylst applies; presume last reasoned ground.	Chatman: Eleventh Circuit may refrain after Harrington.	Eleventh Circuit erred; look-through applies.
Does Richter require look-through when no express reasoning exists?	Hittson relies on Richter to permit look-through.	Richter does not permit speculation beyond stated grounds.	Yes, look-through is required when reasons are not stated.
Is look-through applicable to nondiscretionary state-review denials (certificate of probable cause)?	Nondiscretionary denials fall within Ylst/Richter framework.	Procedural posture may limit applicability.	Look-through applies; cannot rely on speculation.

Ylst v. Nunnemaker, 501 U.S. 797 (1991) (look-through applicable to unexplained state orders)
Richter v. Harrington, 562 U.S. 86 (2011) (look-through to determine grounds for denial or caveat on unexplained orders)
Porter v. McCollum, 558 U.S. 30 (2009) (deferential review of state-court reasoning in habeas corpus)
Rompilla v. Beard, 545 U.S. 374 (2005) (unreasonableness of factual determinations in habeas)
Wiggins v. Smith, 539 U.S. 510 (2003) (unreasonable application of clearly established law under AEDPA)