John Atlas, Jr. v. Eric Arnold, 20-55452

John Atlas Jr. was convicted in California of dissuading witnesses by force or fear (with gang enhancement) after threatening victims when an acquaintance was arrested for stealing their car.
At trial Atlas testified he had schizophrenia and had not taken prescribed medication the night before; defense counsel did not call Atlas’s psychiatrist or a mental-health expert.
On direct appeal the California Court of Appeal rejected Atlas’s Strickland ineffective-assistance claim, finding no prejudice because the jury already heard Atlas’s testimony and the evidence of guilt was overwhelming.
Atlas pursued state habeas relief: the Superior Court denied his petition as unverified and under Waltreus; the California Supreme Court summarily denied a later verified petition.
The federal district court denied habeas relief under 28 U.S.C. § 2254; the Ninth Circuit reviewed de novo and addressed whether AEDPA deference applied and to which state decision.
The Ninth Circuit majority held the California Supreme Court’s summary denial was on the merits (so AEDPA deference applied to the Court of Appeal’s reasoned decision) and affirmed the denial of habeas relief; Judge Watford dissented, arguing an evidentiary hearing was required.

Issue	Atlas's Argument	State/Respondent's Argument	Held
Whether AEDPA deference applies and to which state decision	California Supreme Court’s summary denial should not get look-through deference; claim needs de novo review	Deference applies to last reasoned state decision (Court of Appeal) because California Supreme Court denial was on the merits	Majority: Look-through presumption rebutted; treat CA Supreme Court denial as on the merits and apply AEDPA deference to the Court of Appeal
Whether trial counsel was ineffective for failing to call a psychiatrist/expert (Strickland prejudice)	Failure to investigate/retain an expert was deficient; expert evidence of mania/noncompliance with meds would likely have negated mens rea	Any additional expert testimony would not have created reasonable doubt given Atlas’s own threatening conduct and other strong evidence	Majority: Court of Appeal reasonably concluded no Strickland prejudice; affirm denial of habeas relief
Whether Atlas was entitled to an evidentiary hearing in federal court	Submitted records, declarations, and an expert report that, if credited, state a prima facie claim and warrant an evidentiary hearing	State argues record and credibility issues (e.g., later fraud plea by expert) justify summary denial	Dissent: would remand for evidentiary hearing; Majority: no hearing — state-court resolution not unreasonable under §2254(d)

Strickland v. Washington, 466 U.S. 668 (establishes ineffective-assistance standard)
Harrington v. Richter, 562 U.S. 86 (AEDPA deference to state-court merits determinations)
Ylst v. Nunnemaker, 501 U.S. 797 (look-through presumption and when it may be rebutted)
Wilson v. Sellers, 138 S. Ct. 1188 (apply AEDPA deference to last reasoned state-court decision)
Schriro v. Landrigan, 550 U.S. 465 (district courts must consider AEDPA standards when deciding whether to hold evidentiary hearings)
White v. Woodall, 572 U.S. 415 (clarifies 'unreasonable application' under §2254(d))
Weeden v. Johnson, 854 F.3d 1063 (duty to investigate mental-health defense before forgoing expert)
Earp v. Ornoski, 431 F.3d 1158 (standards for entitlement to evidentiary hearing on habeas)