State review of lawyer mistakes
Calder v. Comerford
In brief
- Where it stands
- Dismissed
Petition denied.
- What it’s about
- Winston Calder asks whether a federal court must give special weight to a Florida court’s finding that he was not harmed by his lawyer’s performance when the state court misunderstood and did not decide whether the lawyer performed unreasonably.
- Who it affects
- Calder did not get Supreme Court review, and the order does not resolve whether a federal court must accept the state court's finding about harm.
Summary: written with AI from the case record.

What it's about
The dispute concerns how federal courts review a state court's decision about whether a defense lawyer's work harmed someone challenging a state conviction.
Question presented
When the deficient performance prong of a claim of ineffective assistance under Strickland v. Washington, 466 U.S. 688 (1984), is misconstrued by the state courts and therefore not adjudicated on the merits in the State court proceedings, is the state courts’ determination as to Strickland’s prejudice prong nonetheless entitled to deference under § 2254(d)?
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Brief added: Petition
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.