Wilson v. Sellers

A federal habeas court should presume that an unexplained decision by a reviewing state court adopts the same reasoning as that provided by the last related lower court opinion unless the state provides evidence of reliance on other grounds.

Petitioner sought a writ of habeas corpus claiming that he received ineffective assistance of counsel during sentencing. The state habeas court denied the petition, holding that counsel’s failure to present evidence of Petitioner’s frontal lobe impairment did not constitute prejudice because such evidence would have been unlikely to affect the outcome of the trial. The state supreme court denied further review without issuing an explanatory opinion. The district court deferred to the state habeas court’s reasoning and conclusion. The circuit court  denied habeas, but held that the district court improperly deferred to the lower court’s reasoning. The United States Supreme Court held that Ylst v. Nunnemaker supported “looking through” an unexplained opinion to the reasoning provided by a lower court. The Court further reasoned that practicality and efficiency justified the “look through” approach, because a higher court’s lack of explanation often results from a lack of significant disagreement with a lower court’s reasoning, and requiring federal courts to imagine reasons supporting a state court’s unexplained decision might involve issues of state law in which a federal court would lack expertise. Accordingly, the Court held that federal courts should presume that an unexplained decision adopts the same reasoning as the last state-court decision. REVERSED and REMANDED.