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Cullen v. Pinholster, 563 U.S. 170, 131 S.Ct. 1388, 179 L.Ed.2d 557, 79 USLW 4229, 11 Cal. Daily Op. Serv. 3995, 2011 Daily Journal D.A.R. 4795, 22 Fla. L. Weekly Fed. S 904

Facts

Scott Lynn Pinholster and two accomplices committed a burglary that resulted in the brutal murder of two men. Pinholster was convicted of first-degree murder and sentenced to death. During the penalty phase, his trial counsel called only his mother as a witness and did not present significant mitigating evidence, despite having consulted with a psychiatrist who diagnosed Pinholster with antisocial personality disorder. After multiple denials of habeas relief in state court, a Federal District Court granted relief based on ineffective assistance of counsel, which was later reversed by the Ninth Circuit.

A California jury convicted respondent Pinholster on two counts of first-degree murder. At the penalty phase before the same jury, the prosecution produced eight witnesses, who testified about Pinholster's history of threatening and violent behavior. Pinholster's trial counsel, who unsuccessfully sought to exclude the aggravating evidence on the ground that the prosecution had not given Pinholster proper notice under California law, called only Pinholster's mother.

Issue

Whether the California Supreme Court's decision regarding Pinholster's ineffective assistance of counsel claim was contrary to or involved an unreasonable application of clearly established federal law.

Whether the California Supreme Court's decision regarding Pinholster's ineffective assistance of counsel claim was contrary to or involved an unreasonable application of clearly established federal law.

Rule

Federal habeas review of state-court proceedings is limited to the record before the state court, and a petitioner must show that the state court's decision was unreasonable under the standards set by the Antiterrorism and Effective Death Penalty Act (AEDPA).

Review under § 2254(d)(1) is limited to the record that was before the state court that adjudicated the claim on the merits.

Analysis

The Supreme Court held that the Ninth Circuit erred by considering new evidence that was not part of the state court record. The Court emphasized that under AEDPA, federal courts must defer to state court decisions and can only grant relief if the state court's decision was unreasonable based on the evidence that was available at the time of its ruling. The Court found that Pinholster's trial counsel had a reasonable strategy and that the state court's conclusion regarding the lack of deficient performance was not unreasonable.

The Supreme Court held that the Ninth Circuit erred by considering new evidence that was not part of the state court record. The Court emphasized that under AEDPA, federal courts must defer to state court decisions and can only grant relief if the state court's decision was unreasonable based on the evidence that was available at the time of its ruling.

Conclusion

The Supreme Court reversed the Ninth Circuit's decision, holding that the California Supreme Court's denial of Pinholster's habeas claim was not an unreasonable application of federal law.

The Supreme Court reversed the Ninth Circuit's decision, holding that the California Supreme Court's denial of Pinholster's habeas claim was not an unreasonable application of federal law.

Who won?

The State of California prevailed in the case because the Supreme Court found that the California Supreme Court's decision was reasonable and consistent with federal law.

The State of California prevailed in the case because the Supreme Court found that the California Supreme Court's decision was reasonable and consistent with federal law.

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