Jefferson S. Dunn, Commissioner, Alabama Department of Corrections v. Matthew Reeves

Federal courts reviewing a state court decision under 28 U.S.C. § 2254(d) must not be “read[y] to attribute error” to a state court for at least two reasons. Woodford v. Visciotti, 537 U.S. 19, 24 (2002). First, federal courts are to “presum[e] that state courts know and follow the law.” Id. And, second, such skeptical review is “incompatible with § 2254(d)’s highly deferential standard for evaluating state-court rulings, which demands that state-court decisions be given the benefit of the doubt.” Id. (cleaned up). The state court here provided several pages of analysis regarding the applicable standard for assessing Matthew Reeves’s ineffective assistance of counsel claim, and the court’s opinion included numerous quotes from and citations to precedents from the Eleventh Circuit and this Court. The state court ultimately concluded that, “[i]n this case, Reeves’s failure to call his attorneys to testify is fatal to his claims of ineffective assistance of counsel.” Pet.App.272a (emphasis added). The Eleventh Circuit read the state court to have held that, “in every case,” failure to call counsel to testify is fatal to an ineffective assistance of counsel claim. And because the state court had purportedly created and used this per se rule that unreasonably applied Strickland v. Washington, 466 U.S. 668 (1984), the Eleventh Circuit was “unconstrained by § 2254’s deference” and was free to assess Reeves’s claim de novo. Pet.App.31a. The court then granted habeas relief. The question presented is whether the Eleventh Circuit violated § 2254(d) by readily attributing error to the state court.