## Facts

- Joshua Richter was convicted in California state court of murder and attempted murder arising from a late-night shooting at a drug dealer’s home and was sentenced to life without parole.
- The prosecution theory was that Richter and a codefendant went to rob the victim; physical evidence and testimony supported the State’s account, including items later found at Richter’s home.
- Defense counsel pursued a theory that the codefendant shot in self-defense and that the fatality resulted from crossfire, seeking to create doubt about the State’s reconstruction.
- Trial counsel did not retain or present independent blood-pattern/forensic experts to support the defense reconstruction, relying instead on cross-examination and argument.
- In state postconviction proceedings, Richter claimed ineffective assistance of counsel for failing to consult or present forensic experts and offered expert affidavits challenging aspects of the State’s forensic case and proposing additional testing.
- The California Supreme Court denied habeas relief in a summary, unexplained order.
- On federal habeas review under 28 U.S.C. § 2254, the district court denied relief; the Ninth Circuit (en banc) granted relief; the Supreme Court reviewed and reversed.

## Issues

1. Whether 28 U.S.C. § 2254(d) applies when a state court denies relief in a summary order without stating reasons.
2. Whether the state court unreasonably applied Strickland v. Washington in rejecting Richter’s ineffective-assistance claim based on counsel’s failure to consult or present forensic experts.

## Decision

- The Supreme Court held that § 2254(d) applies to summary state-court denials and treats them as adjudications on the merits absent indications to the contrary.
- The Court ruled that, when the state court provides no reasoning, the federal habeas court must consider arguments or theories that could have supported the result and deny relief if fairminded jurists could disagree.
- Applying AEDPA deference, the Court concluded the state court could reasonably reject Richter’s Strickland claim on either performance or prejudice grounds.
- The Court reversed the Ninth Circuit’s grant of habeas relief and remanded.

## Legal Principles

- A summary state-court denial is presumed to be an adjudication on the merits for purposes of § 2254(d) unless rebutted by state procedural indicators.
- When the state court does not explain its decision, the federal court asks what rationales supported or could have supported the state result, then determines whether those rationales are inconsistent with clearly established Supreme Court law beyond fairminded disagreement.
- AEDPA permits federal habeas relief only when the state decision is so lacking in justification that no fairminded jurist could agree with it.
- Ineffective-assistance claims on federal habeas receive “doubly” deferential review: deference to counsel’s strategic judgments under Strickland and deference to the state court’s application of Strickland under § 2254(d).
- Under Strickland’s prejudice prong, the likelihood of a different outcome must be substantial, not merely conceivable.

## Conclusion

The Court held that AEDPA’s deferential standard governs even unexplained state habeas denials and that federal courts must uphold such results if any reasonable basis supports them; under this framework, the state court could reasonably reject Richter’s ineffective-assistance claim, so federal habeas relief was unavailable.


Harrington v. Richter, 562 U.S. 86 (2011)