## Facts

- Michael Wayne Williams, a Virginia prisoner sentenced to death for two capital murders, sought postconviction relief after his convictions and sentence were affirmed on direct review.
- In state habeas proceedings, Williams raised three constitutional claims: (1) a Brady claim based on alleged nondisclosure of a psychiatric report concerning accomplice-witness Jeffrey Cruse, (2) juror bias based on a juror’s alleged undisclosed sources of bias during voir dire, and (3) prosecutorial misconduct based on alleged nondisclosure of that juror’s potential bias.
- The state habeas court dismissed the petition.
- Williams then filed a federal habeas petition under 28 U.S.C. § 2254 and requested an evidentiary hearing, asserting he had been unable to develop the factual bases of these claims in state court.
- The federal district court initially granted a hearing on the juror-bias and prosecutorial-misconduct claims but denied a hearing on the Brady claim.
- The Fourth Circuit intervened and directed that AEDPA’s 28 U.S.C. § 2254(e)(2) barred any evidentiary hearing because Williams had “failed to develop” the facts in state court; on remand, the district court dismissed the petition, and the Fourth Circuit affirmed.

## Issues

1. Under 28 U.S.C. § 2254(e)(2), what constitutes a prisoner’s “fail[ure] to develop the factual basis of a claim in State court proceedings”?
2. Does § 2254(e)(2) bar a federal evidentiary hearing on Williams’s juror-bias and prosecutorial-misconduct claims?
3. Does § 2254(e)(2) bar a federal evidentiary hearing on Williams’s Brady claim?

## Decision

- The Supreme Court reversed in part and affirmed in part.
- “Failed to develop” in § 2254(e)(2) is fault-based and is not shown unless the prisoner (or counsel) lacked diligence or was otherwise at fault in state court.
- Because Williams was diligent in state court regarding the juror-bias and prosecutorial-misconduct claims, § 2254(e)(2) did not bar a federal evidentiary hearing on those claims.
- Because Williams did not diligently develop the Brady claim’s factual basis in state court and could not meet § 2254(e)(2)’s statutory exceptions, § 2254(e)(2) barred a federal evidentiary hearing on the Brady claim.

## Legal Principles

- AEDPA § 2254(e)(2) restricts federal habeas evidentiary hearings only when the prisoner’s lack of diligence (or greater fault) caused the undeveloped state-court record.
- Diligence under § 2254(e)(2) turns on whether the prisoner made a reasonable attempt, given available information, to investigate and pursue factual development in state court.
- When the prisoner was diligent, § 2254(e)(2)’s limits do not apply, and the federal court retains discretion to hold a hearing.
- When the prisoner failed to develop the facts due to lack of diligence, a hearing is permitted only if the prisoner satisfies § 2254(e)(2)’s narrow exceptions.

## Conclusion

The Court held that AEDPA’s bar on federal evidentiary hearings depends on the prisoner’s fault: diligent petitioners may obtain hearings despite an incomplete state record, but petitioners who did not diligently develop facts in state court are subject to § 2254(e)(2)’s strict limits and exceptions.


Williams v. Taylor, 529 U.S. 420 (2000)