Michael Sexton, Warden, Petitioner v. Nicholas Beaudreaux

This case asked whether the Ninth Circuit gave too little deference to a state court when it backed an ineffective-assistance-of-counsel claim in a federal habeas case. The Supreme Court said the Ninth Circuit ignored the deferential review required by 28 U.S.C. § 2254(d) and reversed that court's decision.

The Court issued a per curiam opinion reversing the Ninth Circuit; the vote count and any separate writings are not provided in the record here.

“The Court of Appeals' decision ignored well-established principles. It did not consider reasonable grounds that could have supported the state court's summary decision, and it analyzed respondent's arguments without any meaningful deference to the state court.”

The decision reinforces that federal courts must give state-court rulings substantial leeway in habeas cases. For example, a state prisoner claiming poor lawyering will have a harder time winning federal relief if a reasonable judge could agree with the state court.

The Ninth Circuit's ruling in Beaudreaux's favor has been undone. Any further lower-court proceedings must follow the Supreme Court's instruction to apply strong deference to the state court's decision.

The dispute was whether the Ninth Circuit wrongly reweighed an ineffective-assistance claim instead of asking whether reasonable jurists could agree with the state court.

State prisoners seeking federal habeas relief are directly affected. Federal judges reviewing those cases must give more leeway to state-court decisions.

The Ninth Circuit's earlier decision no longer controls. Any next step in lower court must follow the Supreme Court's demand for deferential review under § 2254(d).