Williams v. Hobbs, 131 S. Ct. 558

Petitioner Williams faced capital murder, kidnapping, rape, and aggravated robbery charges; defense conceded guilt in opening statements to gain credibility.
Penalty-phase evidence consisted of a single inmate witness with general life-on-death-row experience; jury imposed death sentence affirmed on direct appeal.
Williams pursued federal habeas corpus under 28 U.S.C. §2254 after state collateral relief denial; district court found trial counsel likely ineffective and awarded relief.
Habeas hearing presented extensive childhood trauma evidence; district court concluded prejudice from counsel’s performance and ordered new penalty trial or reduced sentence.
Eighth Circuit reversed, holding no proper federal evidentiary hearing entitlement and declining relief; alternatively, it claimed discretionary review of district court’s §2254(e)(2) noncompliance.
Sotomayor, dissenting, argues the State improperly manipulated the process and that the Court should review and vacate the lower judgment to prevent misuse of hearings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State properly preserved an objection to the evidentiary hearing	Williams argues the State failed to preserve an objection; record shows no notice of challenge.	State contends it objected to the hearing in the district court.	Dissent: objection not preserved; State consented, not objected
Whether the Eighth Circuit could review post-hearing, untimely §2254(e)(2) objections	State’s later objection was untimely and not properly before appellate review.	Day v. McDonough allows sua sponte review of timeliness in certain contexts.	Dissent: Day does not permit this post-hoc defense; no proper basis for review
Whether Day and Granberry require consideration of strategic forfeiture and prejudice	Record suggests the State strategically used the hearing; should be reviewed for strategic forfeiture and prejudice.	The court need not search for strategic forfeiture where objection was untimely.	Dissent: record shows strategic use; court must assess to avoid miscarriage of justice
Whether the interests of justice require allowing review of untimely objection	Allowing late objections harms justice by enabling state manipulation of habeas process.	Federal habeas policy emphasizes finality and comity; delay objections undermine process.	Dissent: interests of justice demand review and possible vacatur

Day v. McDonough, 547 U.S. 198 (U.S. 2006) (discretion to consider timeliness sua sponte; not to be used to embrace strategic forfeiture)
Granberry v. Greer, 481 U.S. 129 (U.S. 1987) (whether interests of justice require review of undisputed strategic decisions)
Puckett v. United States, 556 U.S. 129 (U.S. 2009) (contemporaneous-objection rule to prevent sandbagging)
Bech Aircraft Corp. v. Rainey, 488 U.S. 153 (U.S. 1988) (preserving objections and notice requirements)
Bradshaw v. Richey, 546 U.S. 74 (U.S. 2005) (preserving objections on appeal per curiam remand discussion)
Holland v. Jackson, 542 U.S. 649 (U.S. 2004) (per curiam; preservation of objections on record)
Williams v. Taylor, 529 U.S. 420 (U.S. 2000) (principles of comity and federalism in habeas review)