The US Supreme Court [official website] ruled [opinion, PDF] unanimously Wednesday in Johnson v. Williams [JURIST report] that in Tara Williams' case, the California Court of Appeal properly adjudicated her federal Sixth Amendment [text] claim on its merits and should have been deferred to under the Antiterrorism and Effective Death Penalty Act of (AEDPA) [28 USC § 2254(d) text]. The Court held that this deference is proper, and although the California Court of Appeal did not explicitly deal with Williams' federal claim that her right to an impartial jury trial was violated, it did in a matter that satisfied the AEDPA. Justice Samuel Alito wrote for the Court, which found the case was controlled by last term's Harrington v. Richter [JURIST report].
Although Richter itself concerned a state-court order that did not address any of the defendant's claims, we see no reason why the Richter presumption should not also apply when a state-court opinion addresses some but not all of a plaintiff's claims. There would be a reason for drawing a distinction between these two situations if opinions issued by state appellate courts always separately addressed every single claim that is mentioned in a defendant's papers. If there were such a uniform practice, then federal habeas courts could assume that any unaddressed federal claim was simply overlooked.The Court found that for an adequate habeas claim the defendant must prove the state court "inadvertently overlooked" a federal claim. Alito suggested that it was "exceedingly unlikely" that the California Court of Appeal had overlooked Williams' claim, and relied partially on Williams treating her federal and state claims as interchangeable. "Williams presumably knows her case better than anyone else, and the fact that she does not appear to have thought that there was an oversight makes such a mistake most improbable."
Justice Antonin Scalia concurred in the judgment but not the reasoning, suggesting the Court does not need to engage in analysis over whether a lower court "overlooked" a claim a plaintiff raised. "Only after conducting its own detective work does the Court conclude that the federal claim was not overlooked in this case. This complex exercise is unnecessary. A judgment that denies relief necessarily denies—and thus adjudicates—all the claims a petitioner has raised."