Takeaway
In short, this case established AEDPA's central distinction between an incorrect and an objectively unreasonable state-court application of Supreme Court law, while holding that counsel's failure to uncover and present powerful capital mitigation evidence violated Strickland.
Terry Williams was convicted in Virginia of capital murder and robbery for killing Harris Stone with a mattock and taking money from him. At sentencing, the State introduced Williams' prior convictions, confessions to other violent crimes, evidence of later assaults and arsons, and expert testimony that he posed a high probability of future dangerousness. Defense counsel presented only sparse testimony from Williams' mother and neighbors, plus a limited psychiatric recording, and principally argued that Williams had voluntarily confessed to crimes the police otherwise would not have solved. The jury imposed death.
In state habeas proceedings, the trial judge who had presided over the capital trial found that counsel's sentencing performance was deficient and prejudicial. Counsel had failed to investigate and present extensive mitigating evidence: records of severe childhood neglect and abuse; evidence that Williams was borderline intellectually disabled and had suffered head injuries; prison records and witnesses showing that he functioned well in structured settings; and favorable character evidence. The Virginia Supreme Court assumed deficient performance but found no prejudice, reasoning that Lockhart v. Fretwell required more than an outcome-based inquiry and that the omitted evidence would barely have changed Williams' profile.
A federal district court granted habeas relief, but the Fourth Circuit reversed. Applying its AEDPA standard, the Fourth Circuit held that relief was unavailable unless all reasonable jurists would agree that the state court's application of Supreme Court precedent was unreasonable. The Supreme Court reversed the Fourth Circuit and remanded.
Issue #1
Whether AEDPA's requirement of “clearly established Federal law” permits federal habeas relief based on lower-court precedent or Supreme Court dicta.
Holding
No. Under 28 U.S.C. § 2254(d)(1), clearly established federal law consists of the Supreme Court's holdings, rather than its dicta or lower federal court decisions, as of the time of the relevant state-court decision.
Reasoning
AEDPA limits the legal source for habeas relief to law “as determined by the Supreme Court of the United States.” That restriction extends the anti-new-rule principle associated with Teague v. Lane: a state prisoner ordinarily cannot obtain collateral relief by invoking a constitutional rule not already established when the state court acted.
The controlling law may be stated as a general standard rather than a fact-specific rule. Strickland's two-part ineffective-assistance framework was therefore clearly established federal law even though applying it requires a case-by-case assessment of counsel's performance and resulting prejudice.
Issue #2
What do AEDPA's “contrary to” and “unreasonable application” clauses require of a federal habeas court reviewing a state court's merits decision?
Holding
A state decision is “contrary to” Supreme Court precedent when it reaches the opposite legal conclusion or decides materially indistinguishable facts differently; it involves an “unreasonable application” when it identifies the correct governing rule but applies it to the facts in an objectively unreasonable manner. An unreasonable application is more than a merely incorrect one.
Reasoning
Justice O'Connor's controlling construction gave independent force to both statutory clauses. The “contrary to” clause covers a state court that applies a rule contradicting the Supreme Court's governing rule, or reaches an opposite result on materially indistinguishable facts. The “unreasonable application” clause covers a state court that correctly states the governing principle but applies it unreasonably to the prisoner's case.
The inquiry is objective. The Fourth Circuit erred by asking whether all reasonable jurists would agree that the state court was unreasonable. The existence of a judge who might share the state court's view does not itself establish that the decision was objectively reasonable.
The Court also rejected the proposition that AEDPA permits relief whenever a federal court would decide the constitutional question differently. Congress used “unreasonable,” not “incorrect,” and thus imposed a real constraint on federal habeas relief. At the same time, AEDPA does not require federal courts to accept a state court's objectively unreasonable application of Supreme Court law.
Issue #3
Whether the Virginia Supreme Court's rejection of Williams' ineffective-assistance claim was contrary to, or an unreasonable application of, Strickland v. Washington.
Holding
Yes. The state court's decision was contrary to Strickland because it treated Lockhart v. Fretwell as modifying Strickland's ordinary prejudice test, and it was an unreasonable application of Strickland because it failed to assess the totality of the mitigating evidence against the aggravating evidence.
Reasoning
Strickland requires a defendant to show deficient performance and a reasonable probability that, absent counsel's errors, the result would have been different. A reasonable probability is one sufficient to undermine confidence in the result. In the ordinary case, that outcome-focused inquiry is the governing test for prejudice.
Lockhart did not alter Strickland for this case. Lockhart addressed an unusual situation in which counsel's error denied the defendant only a benefit derived from a legal rule later determined to be invalid. Williams, by contrast, was deprived of his constitutional right to present available mitigating evidence to the capital sentencing jury. His prejudice claim thus required a straightforward Strickland analysis.
Counsel's performance at sentencing was deficient. They began preparing late, failed to investigate Williams' background because they mistakenly believed state law barred access to relevant records, did not seek prison evidence of his good conduct, and failed even to return a promising character witness's call. These omissions were not informed strategic choices and fell below reasonable professional standards.
The omitted evidence was substantial and materially different from the limited presentation at trial. It documented Williams' severely abusive and neglectful childhood, intellectual limitations, possible organic impairment, ability to function safely in structured environments, and positive conduct while incarcerated. It also supplied a fuller basis for the jury to assess his moral culpability and the possibility of a nonviolent life in prison.
The Virginia Supreme Court unreasonably minimized this evidence as largely cumulative testimony from relatives that Williams was nonviolent. It failed to reweigh the total mitigating record—including the evidence offered at trial that Williams confessed and cooperated with police—against the State's aggravating proof. The same trial judge who had imposed death concluded that the omitted evidence created a reasonable probability of a different sentence, and the Supreme Court agreed that Williams had established Strickland prejudice.