Crosley Alexander Green v. Ricky D. Dixon, Secretary, Florida Department of Corrections, et al.

Principles of federalism and comity embodied in the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. § 2254, require deference to state court factfinding and procedures in connection with federal habeas proceedings. Here, a Florida state court determined that Petitioner had exhausted state procedures on the relevant claims. With that as background, the federal district court granted a writ of habeas corpus to Petitioner because the State had unlawfully failed to disclose exculpatory evidence— the prosecutor’s notes reflecting material observations and conclusions of the responding officers—as required by Brady v. Maryland, 373 U.S. 83 (1963). The Eleventh Circuit reversed, effectively overruling determinations of both fact and of the state’s own procedures made by the state court, thereby adopting an approach that stands in stark contrast to the approach set out by this Court and applied in other Circuits. The following questions are presented:

1. Where Petitioner’s state high court brief articulated the federal constitutional guarantee relied upon and the facts supporting that claim, and a state trial court determined that Petitioner’s Brady claim had been presented to that court and “appeal[ed] to the Supreme Court of Florida,” is it proper for a federal habeas court on appeal to redefine the claim presented to the state high court, to make it “coincide” with a claim presented in state trial court pleadings, to conclude that the habeas claim was not properly exhausted in the state courts?

2. Does it violate the presumption of correctness of state court factual determinations for a federal