Wilson v. Sellers

Justia Summary

Wilson was convicted of murder and sentenced to death. He unsuccessfully sought habeas relief in Georgia courts, claiming ineffectiveness of counsel during sentencing. The Georgia Supreme Court summarily denied relief. Wilson filed a federal habeas petition, raising the same ineffective-assistance claim. The district court assumed that his counsel was deficient but deferred to the state court’s conclusion that any deficiencies did not prejudice Wilson. The Eleventh Circuit affirmed. The Supreme Court reversed, rejecting the Eleventh Circuit's methodology. A federal habeas court reviewing an unexplained state-court decision on the merits should “look through” that decision to the last related state-court decision that provides a relevant rationale and presume that the unexplained decision adopted the same reasoning. The state may rebut the presumption by showing that the unexplained decision most likely relied on different grounds. The presumption is often realistic; state higher courts often issue summary decisions when they have examined the lower court’s reasoning and found nothing significant with which they disagree. The presumption also is often more efficient than requiring a federal court to imagine what might have been the state court’s supportive reasoning. The “look through” presumption is not an absolute rule and does not show disrespect for the states but seeks to replicate the grounds for the higher state court’s decision.