Ramon Ruelas v. Troy Bowser, 20-35899

Ramon Torres Ruelas petitioned for federal habeas relief under 28 U.S.C. § 2254 after the Oregon courts denied his post-conviction relief; the Ninth Circuit reviews the district court’s denial de novo and affirms.
The Oregon circuit court’s May 2016 reasoned decision is treated as the last related state-court rationale under the "look through" rule because the highest state court’s decision was unreasoned.
Ruelas alleged trial counsel provided ineffective assistance by failing to investigate and call additional lay witnesses and by not presenting expert testimony to undermine the victims’ credibility/memory.
At trial, victims gave graphic, consistent testimony and described sexual content matching videos found at Ruelas’s residence; trial counsel pursued a strategy attacking credibility and arguing Ruelas was not alone with the victims.
The state court found many proposed lay witnesses were unknown to trial counsel or lacked contact information, that their testimony would be duplicative or of little weight given the judge’s focus on victims’ credibility, and that the habeas-stage expert did not show defects in the victims’ memories.
Applying AEDPA deference to Strickland, the Ninth Circuit concluded the state court’s determinations were not unreasonable and affirmed the denial of habeas relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for failing to investigate and present additional lay witnesses	Ruelas: counsel failed to locate/call relevant lay witnesses whose testimony would have supported his defense	State: many witnesses were not identified to counsel or contactable; testimony would be duplicative or carry little weight	Court: No ineffective assistance—state court reasonably found counsel not deficient and no prejudice
Whether counsel was ineffective for not presenting expert testimony challenging victims’ credibility/memory	Ruelas: an expert could have shown implanted or unreliable memories, undermining victims’ testimony	State: habeas-stage expert did not identify concrete problems; trial judge emphasized victims’ credibility; expert unlikely to change outcome	Court: No ineffective assistance—state court reasonably concluded expert evidence was not shown to be deficient or prejudicial
Whether AEDPA deference permits relief where state court applied Strickland	Ruelas: Strickland was misapplied to his case and relief is warranted	State: under AEDPA petitioner must show state court unreasonably applied Strickland or unreasonably found facts	Court: AEDPA bars relief—state court’s application of Strickland was not objectively unreasonable

Carter v. Davis, 946 F.3d 489 (9th Cir. 2019) (standard of review for district court denial of § 2254 relief)
Wilson v. Sellers, 138 S. Ct. 1188 (2018) ("look through" rule for unexplained state-court decisions)
Strickland v. Washington, 466 U.S. 668 (1984) (two-part ineffective-assistance-of-counsel test)
Bell v. Cone, 535 U.S. 685 (2002) (AEDPA requires showing state court unreasonably applied Strickland)
Harrington v. Richter, 562 U.S. 86 (2011) (state-court determinations entitled to deference unless beyond fairminded disagreement)