Darryl Scott Stinski v. Shawn Emmons, Warden

Under 28 U.S.C. § 2254(d)(2), habeas applications may be granted where the state court’s adjudication of the claim “resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.” Courts have disagreed about the relationship between this deferential standard and the separate standard set forth in § 2254(e)(1) that a state court’s factual determinations “shall be presumed to be correct” absent “clear and convincing evidence” to the contrary. 28 U.S.C. § 2254(e)(1). This Court previously granted certiorari to address these provisions’ interplay in Wood v. Allen, 558 U.S. 290, 299 & n.1 (2010), but declined to resolve the issue. In the decision below, the Eleventh Circuit panel, bound by recent en banc precedent, asserted that courts should apply both deferential standards to habeas claims regardless of whether petitioners have presented new evidence outside the state court record. While many circuits agree, as this Court noted in Wood, that issue “has divided the Courts of Appeals,” id. at 299. The question presented is: Whether the evidentiary standard in § 2254(e)(1) does not apply when a state prisoner seeks federal habeas relief solely on the state court evidentiary record and introduces no new evidence to attack the state court’s factual determinations. (i)