Alvaro Quezada v. James Hill, Warden

Petitioner Alvaro Quezada is serving life without the possibility of parole for his alleged involvement in the murder of his cousin’s husband, Bruce Cleland, based on the testimony of Joseph Aflague, “the only witness that linked Quezada directly to the murder . . . .” After Aflague revealed for the first time at trial that he had worked in the past as an informant, but swore he was expecting nothing for his testimony in Quezada’s case, post-conviction productions of previously undisclosed information revealed Aflague’s constant reliance on law enforcement for funds in exchange for his cooperation, including at the time of, and “intertwined” with, Quezada’s trial, triggering habeas claims under Napue v. Illinois, 360 U.S. 264 (1959) and Brady v. Maryland, 373 U.S. 83 (1963). But when presented with this evidence, the state court failed to perform the Napue analysis this Court required in Glossip v. Oklahoma, 145 S. Ct. 612 (2025), and the district court overruled the lookthrough presumption and held instead that the claim had been silently denied on its merits without assessing the state court’s opinion. The Ninth Circuit then summarily denied even a certificate of appealability (“COA”), effectively deeming these decisions “not even debatable.” Buck v. Davis, 580 U.S. 100, 116 (2017). The question presented is thus: did the Ninth Circuit’s summary denial of a COA here so clearly misapply Glossip’s mandate regarding Napue and Buck’s modest standard for granting a COA as to call for reversal and remand?