Plain-English summary
Court limits federal habeas review of evidence outside state-court record tied to ineffective postconviction counsel
The Court held that 28 U.S.C. §2254(e)(2) bars federal habeas courts from holding evidentiary hearings or considering evidence beyond the state-court record when the new evidence is tied to ineffective assistance by state postconviction counsel. The judgment reversing the Ninth Circuit was issued on May 23, 2022.
Why this matters
This decision tightens the limits on federal habeas review by making it harder for prisoners to introduce new factual evidence in federal court when that evidence was not developed in state postconviction proceedings — even if the reason it wasn’t developed was poor performance by the state postconviction lawyer. It affects the ability of federal courts to correct potential miscarriages of justice that depend on facts outside the state record.
Who may feel it
- People convicted in state court seeking federal habeas relief
- State and federal public defenders and postconviction counsel
- Victims and families involved in state criminal convictions
- Courts evaluating procedural bars and habeas evidence
Key questions