King v. Greiner, 453 F. App'x 88

King challenges a July 13, 2009 district court judgment denying habeas relief under 28 U.S.C. §2254 following a July 8, 2009 denial order and certificate of appealability.
Evidence against King included two eyewitness identifications at lineups and trial, and King’s own identification of accomplices to police; alibi defenses were shown to be fabricated.
Trial testimony largely corroborated the prosecutions’ case; King’s testimony reinforced guilt.
King’s ineffective assistance of counsel claim centered on failure to object to comments in the prosecutor’s second summation.
State court analysis and AEDPA framework govern review, with the district court’s factual findings substantial and the record showing strong confidence in guilt.
Court ultimately affirmed the district court’s denial of habeas relief, applying de novo review to the ineffective-assistance claim

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether King’s claim is reviewed de novo or under AEDPA deference.	King	Greiner	De novo review applied (or AEDPA deference unnecessary) per court’s reasoning
Whether counsel’s failure to object to the second summation was deficient performance.	King	Greiner	No prejudice; strong evidence of guilt undermines likelihood of different outcome
Whether, under Strickland, King showed prejudice given the evidence.	King	Greiner	Prejudice not shown; substantial evidence of guilt defeats the claim

Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-prong ineffective assistance standard)
Harrington v. Richter, 562 U.S. 86 (2011) (reasonableness of trial counsel’s performance under Strickland)
Williams v. Taylor, 529 U.S. 362 (2000) (clarifies unreasonable application of governing legal principle)
Dolphy v. Mantello, 552 F.3d 236 (2d Cir. 2009) (de novo review when claim not adjudicated on merits)
Hawkins v. Costello, 460 F.3d 238 (2d Cir. 2006) (standard of review for habeas corpus determinations)