Holloman v. Clarke

1. Whether the state court's summary disposition of a claim that it lacked jurisdiction to hear constitutes an "adjudication on the merits" under 28 U.S.C. § 2254(d)? 2. Whether the Fourth Circuit's decision, which held that a state court's summary denial of a habeas petition is an adjudication on the merits under 2254(d) even when the state court lacks jurisdiction to hear the claim, conflicts with this Court's precedent in Harrington v. Richter, 562 U.S. 86 (2011) and Johnson v. Williams, 568 U.S. 289 (2013)?