Mays v. Hines, 592 U.S. 385

In 1985 Anthony Hines was convicted in Tennessee of murdering motel maid Katherine Jenkins; evidence included Jenkins’ missing car, Hines found with her car and keys, dried blood on his shirt, multiple inconsistent statements, and a history of carrying a knife.
Kenneth Jones discovered the body and testified at trial; defense highlighted oddities in his testimony but did not aggressively investigate or expose Jones’ long-term affair at the motel.
Postconviction, Jones later admitted he routinely visited the motel with a companion; Tennessee courts considered Hines’s ineffective-assistance claim and rejected it, emphasizing the strong evidence of Hines’s guilt and finding no prejudice under Strickland.
A divided Sixth Circuit granted habeas relief, concluding counsel should have more forcefully pursued Jones as an alternative suspect or impeached him, and that this created a substantial likelihood of a different result.
The Supreme Court, in a per curiam opinion, reversed: it held the Sixth Circuit failed to give proper deference under AEDPA to the Tennessee court’s reasoned Strickland decision and ignored overwhelming evidence of Hines’s guilt. Justice Sotomayor dissented.

Issue	Plaintiff's Argument (Hines)	Defendant's Argument (Warden/State)	Held
Whether counsel’s failure to investigate and present Jones’ affair and other impeachment evidence amounted to ineffective assistance under Strickland	Trial counsel should have fully exposed Jones’ affair and portrayed him as an alternative suspect; that would have created a substantial likelihood of a different result	Trial counsel made a strategic choice to avoid embarrassing lines of attack; even if counsel erred, Tennessee reasonably found no prejudice given strong guilt evidence	No; Tennessee reasonably applied Strickland and federal courts must defer under AEDPA, so habeas relief was improper
Whether the Sixth Circuit properly granted habeas relief under 28 U.S.C. §2254(d) (AEDPA)	The Sixth Circuit could reassess prejudice and the likely effect of additional investigation	AEDPA requires federal courts to defer unless state court decision was objectively unreasonable; the Sixth Circuit ignored much of the record showing guilt	Reversed: Sixth Circuit failed to give required deference and omitted key evidence supporting the state court’s conclusion

Strickland v. Washington, 466 U.S. 668 (establishing ineffective-assistance standard)
Harrington v. Richter, 562 U.S. 86 (AEDPA deference is difficult to overcome)
Cullen v. Pinholster, 563 U.S. 170 (prejudice standard in habeas ineffective-assistance claims)
Knowles v. Mirzayance, 556 U.S. 111 (state-court latitude in assessing prejudice)
Shinn v. Kayer, 592 U.S. _ (per curiam) (federal courts must not disturb state judgments under AEDPA absent lack of fairminded disagreement)