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Case Dealing with AEDPA Presumption of Factual Findings' Correctness

In Jefferson v. Upton, No. 09-8852, a capital habeas matter, the Supreme Court vacated the Eleventh Circuit's affirmance of a denial of petitioner's habeas petition, holding that the court of appeals did not fully consider several remaining potentially applicable exceptions to the presumption of correctness given to state court factual findings under 28 U.S.C. sections 2254(d)(1)-(8).

As the Court wrote:  "Petitioner Lawrence Jefferson, who has been sentenced to death, claimed in both state and federal courts that his lawyers were constitutionally inadequate because they failed to investigate a traumatic head injury that he suffered as a child. The state court rejected that claim after making a finding that the attorneys were advised by an expert that such investigation was unnecessary. Under the governing federal statute, that factual finding is presumed correct unless any one of eight exceptions applies. See 28 U.S.C. §§2254(d)(1)-(8) (1994 ed.). But the Court of Appeals considered only one of those exceptions (specifically §2254(d)(8)). And on that basis, it considered itself "duty-bound" to accept the state court's finding, and rejected Jefferson's claim. Because the Court of Appeals did not fully consider several remaining potentially applicable exceptions, we vacate its judgment and remand."

Related Resources

Full Text of Jefferson v. Upton, No. 09-8852