Wilson v. Sellers
138 S. Ct. 1188
| SCOTUS | 2018Background
- Marion Wilson was convicted of murder in Georgia (1997) and sentenced to death; state direct review affirmed and certiorari to SCOTUS denied.
- Wilson filed state postconviction habeas raising ineffective-assistance-at-sentencing under Strickland, presenting new mitigation evidence (childhood testimony, alleged frontal-lobe impairment).
- Georgia Superior Court denied relief on both prongs (no deficient performance; no prejudice) and the Georgia Supreme Court denied a certificate to appeal without opinion.
- Wilson filed federal habeas; the District Court assumed deficiency but deferred to state-court no-prejudice finding; Eleventh Circuit panel rejected the District Court’s “look-through” reliance and applied a “could have supported” approach; en banc Eleventh Circuit affirmed that methodology.
- Supreme Court granted certiorari to resolve a circuit split over whether a federal habeas court should "look through" an unexplained state-court merits decision to the last reasoned state decision and presume the same rationale.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal habeas courts should "look through" an unexplained state-court merits ruling to the last reasoned state decision and presume it adopted that rationale | Wilson: federal courts should look through to the last reasoned state opinion and presume the higher court adopted that reasoning (presumption rebuttable) | Georgia/Warden: Richter controls; federal court should ask what arguments "could have supported" the unexplained ruling rather than presume adoption of the lower court's reasoning | Held: Adopt a rebuttable "look through" presumption: federal courts should look through to the last reasoned state decision and presume the unexplained decision adopted its reasoning, but the State may rebut by showing other grounds were more likely relied on |
| What standard governs rebuttal of the presumption | Wilson: presumption is appropriate and can be rebutted by convincing alternative grounds presented to the higher court or obvious in the record | State: Richter requires considering any reasonable basis that "could have supported" the unexplained decision; presumption is inconsistent with AEDPA and appellate practice | Held: Presumption is not absolute; rebuttable by convincing alternative grounds briefed/argued to the state high court or obvious alternative grounds in the record; federal courts may still deny relief on any reasonable basis consistent with AEDPA |
| Whether Richter precludes applying Ylst-style presumption when there is a lower reasoned opinion | Wilson: Ylst presumption applies; Richter does not negate Ylst in this context | State/Dissent: Richter governs AEDPA review and requires considering any possible reasonable basis; look-through presumption conflicts with AEDPA and traditional appellate norms | Held: Richter does not foreclose look-through in this context; Court explains Richter concerns different factual posture (no lower reasoned opinion) and endorses look-through subject to rebuttal |
| Practical effect on habeas review and state-court respect | Wilson: look-through is realistic and efficient; respects state-court decision-making | State/Dissent: look-through disrespects state courts, conflicts with appellate practice, and will cause burdens or procedural consequences | Held: Court rejects respect argument as dispositive; finds look-through more likely to replicate actual grounds and is narrow in purpose under AEDPA; unlikely to meaningfully increase state burdens |
Key Cases Cited
- Ylst v. Nunnemaker, 501 U.S. 797 (presumption that later unexplained orders adopt reasoning of last reasoned state judgment)
- Harrington v. Richter, 562 U.S. 86 (AEDPA review permits summary dispositions; petitioner must show no reasonable basis existed for state denial)
- Premo v. Moore, 562 U.S. 115 (deference to reasoned state postconviction court decisions under AEDPA)
- Strickland v. Washington, 466 U.S. 668 (two-prong ineffective-assistance standard: deficient performance and prejudice)
- Porter v. McCollum, 558 U.S. 30 (federal review of state-court merits where reasons are given)
- Rompilla v. Beard, 545 U.S. 374 (deference to state-court factual and legal findings in ineffective-assistance context)
- Wiggins v. Smith, 539 U.S. 510 (review of ineffective-assistance claims and deference to state-court reasoned rulings)