Sumner v. Mata

Summary

The Supreme Court held that, in federal habeas proceedings, the factual findings underlying a state court's determination regarding the constitutionality of pretrial identification procedures are entitled to the presumption of correctness under 28 U.S.C. § 2254(d). Although the ultimate constitutional question is a mixed question of law and fact not governed by that presumption, federal courts must address and explain any disagreement with state-court factual findings. The Court vacated the Ninth Circuit's judgment and remanded for further proceedings.

Holdings

1. The presumption of correctness under 28 U.S.C. § 2254(d) applies to the historical and subsidiary factual findings underlying the constitutional determination whether a pretrial identification procedure was impermissibly suggestive.
2. The ultimate question whether pretrial photographic identification procedures were impermissibly suggestive is a mixed question of law and fact to which the § 2254(d) presumption of correctness does not apply.
3. The Ninth Circuit failed to comply with the Supreme Court's prior remand and with § 2254(d) because it neither applied the presumption of correctness to the disputed factual findings nor adequately explained why the presumption did not control.

Questions Presented

1. Whether the Ninth Circuit complied with the Supreme Court's prior remand requiring application of 28 U.S.C. § 2254(d)'s presumption of correctness to state-court factual findings or a written explanation for declining to apply it.
2. Whether the presumption of correctness under § 2254(d) applies to the underlying historical facts supporting the ultimate constitutional determination that a pretrial photographic identification procedure was impermissibly suggestive.
3. Whether the Ninth Circuit's judgment granting habeas relief should be vacated and remanded for further proceedings.

Disposition

vacated