Sumner v. Mata

Summary

The Supreme Court held that 28 U.S.C. § 2254(d) requires federal habeas courts to apply a presumption of correctness to factual determinations made by state courts, including state appellate courts. When a federal habeas court grants relief despite those state-court determinations, it must explain why one of the statutory exceptions applies or why the state finding is not fairly supported by the record. The Court vacated and remanded the Ninth Circuit’s judgment without deciding the merits of the allegedly suggestive identification procedure.

Holdings

1. Former § 2254(d) applies to factual determinations made by a state appellate court as well as those made by a state trial court, provided the statutory requirements for a determination after a hearing on the merits are satisfied.
2. A federal habeas court granting a writ under § 2254 must state the reasoning that led it to conclude that one of the statutory exceptions to the presumption of correctness applies or that the state-court factual determination is not fairly supported by the record.
3. The Ninth Circuit judgment must be vacated because the court did not apply or explain its treatment of the § 2254(d) presumption of correctness.

Questions Presented

1. Whether former 28 U.S.C. § 2254(d) applies to factual determinations made by a state appellate court after review of the trial record.
2. Whether a federal habeas court granting relief must provide a reasoned explanation showing why the § 2254(d) presumption of correctness does not apply or why the state-court finding is not fairly supported by the record.
3. Whether the Ninth Circuit's judgment should be affirmed on the merits of the allegedly impermissibly suggestive identification procedure.

Disposition

vacated