## Facts

- Alberto Valdez was convicted in Texas state court of capital murder for killing a police sergeant and was sentenced to death after the jury answered Texas capital sentencing special issues against him.
- On state habeas review, Valdez claimed trial counsel were ineffective at sentencing for failing to investigate and present mitigation evidence, including alleged intellectual disability, childhood abuse, and positive prison behavior.
- The state habeas court conducted a multi-day evidentiary process, received evidence and argument, and issued written findings and conclusions denying relief.
- Valdez sought federal habeas relief under 28 U.S.C. § 2254; the district court concluded the state proceeding was not “full and fair,” declined to apply AEDPA deference, held its own evidentiary hearing, excluded several state exhibits concerning intellectual functioning, and granted relief on ineffective-assistance grounds.
- The state appealed, challenging the district court’s refusal to apply § 2254(d) and (e)(1) and the exclusion of four exhibits relevant to the intellectual-disability mitigation theory.

## Issues

1. Whether a federal habeas court may refuse to apply AEDPA deference under 28 U.S.C. § 2254(d) and (e)(1) because it believes the state habeas proceeding was not “full and fair.”
2. Whether the district court abused its discretion by excluding four state exhibits bearing on whether trial counsel were ineffective for not investigating and presenting evidence of alleged intellectual disability at sentencing.

## Decision

- The Fifth Circuit held that a “full and fair hearing” is not a prerequisite to applying AEDPA’s deferential review scheme once a claim has been adjudicated on the merits in state court.
- The court vacated the district court’s grant of habeas relief and remanded for reconsideration under § 2254(d) and (e)(1).
- The court affirmed in part and vacated in part the district court’s evidentiary rulings, holding it was an abuse of discretion to exclude four exhibits relevant to Valdez’s intellectual functioning.

## Legal Principles

- When a state court has adjudicated a claim on the merits, federal habeas review is governed by AEDPA’s limits in § 2254(d), and state factual findings are presumed correct under § 2254(e)(1) unless rebutted by clear and convincing evidence.
- Federal courts may not create an extra-statutory “full and fair hearing” threshold to bypass § 2254(d) and (e)(1); alleged deficiencies in state proceedings must be addressed within AEDPA’s framework.
- Excluding probative evidence as a sanction in federal habeas requires an appropriate basis tied to the federal proceeding; alleged discovery failures in earlier state proceedings do not, without more, justify exclusion of relevant evidence in federal court.

## Conclusion

The Fifth Circuit ruled that AEDPA deference applies to state merits adjudications without any separate “full and fair hearing” requirement, vacated the federal habeas grant, and remanded for review under § 2254(d) and (e)(1) while also rejecting the district court’s exclusion of key exhibits related to Valdez’s intellectual-disability mitigation theory.


Valdez v. Cockrell, 274 F.3d 941 (5th Cir. 2001)