Jeffrey Weller v. Ronald Haynes, 23-35459

Jeffrey and Sandra Weller (“the Wellers”) filed a consolidated habeas corpus petition alleging ineffective assistance of trial counsel (IAC) after being denied relief in state court in Washington.
The Washington Supreme Court Commissioner denied their petition based on a state procedural rule (the "inadequate briefing rule" set out in In re Rice), rather than on the merits.
The Wellers neither had counsel nor could raise their IAC claim until collateral post-conviction review, as required by Washington law.
The Wellers diligently tried to supplement the record with evidence and repeatedly requested an attorney and an evidentiary hearing while acting pro se from prison.
The district court denied their habeas petition, finding they had not met the requirements for an evidentiary hearing and that the state decision was not independent of federal law.
On appeal, the Ninth Circuit reversed and remanded, instructing the district court to hold an evidentiary hearing and address whether the Wellers' IAC claim has merit (is “substantial”).

Issue	Wellers' Argument	Respondents' Argument	Held
Was the state court denial independent of federal law?	It was a state procedural bar, not a merits ruling.	It was not independent; federal merits review applies.	State court denial was independent of federal law.
Can Wellers overcome procedural default based on lack of counsel and nature of Washington law?	Yes, because they had no post-conviction counsel and had to raise IAC for the first time then.	No specific argument detailed.	Wellers established cause for the default due to lack of counsel and state requirements.
Did Wellers fail to diligently develop the record, barring an evidentiary hearing under § 2254(e)(2)?	No, they acted diligently pro se and sought evidence.	Yes, they failed to request funds for expert evidence.	Wellers demonstrated diligent effort; evidentiary hearing required.
Was the district court’s review of the magistrate’s report adequate?	Yes, review and consideration were sufficient.	No explicit indication of standard used.	District court fulfilled its 28 U.S.C. § 636(b)(1)(C) obligations.

Harris v. Reed, 489 U.S. 255 (procedural default bars federal review if state court clearly relies on independent state law)
Coleman v. Thompson, 501 U.S. 722 (procedural bar rules must be independent and adequate to preclude federal review)
Martinez v. Ryan, 566 U.S. 1 (lack of counsel on collateral review can establish cause for default on IAC claims)
Williams v. Taylor, 529 U.S. 420 (diligence in developing the state court record analyzed under § 2254(e)(2))
Cullen v. Pinholster, 563 U.S. 170 (federal habeas review limited to state court record on merits adjudication)
Ake v. Oklahoma, 470 U.S. 68 (federal courts must defer to state court findings on independent state law grounds)