Reid v. True
United States Court of Appeals for the Fourth Circuit
349 F.3d 788 (2003)
- Written by Arlyn Katen, JD
Facts
James Reid (defendant) filed a federal habeas petition that challenged the Virginia Supreme Court’s rejection of his ineffective-assistance-of-counsel (IAC) claim. The Virginia Supreme Court rejected Reid’s IAC claim without providing any reasoning for its decision. At the time that the Virginia Supreme Court rejected Reid’s IAC claim, that court sometimes applied an IAC rule that the United States Supreme Court eventually declared unconstitutional in Williams v. Taylor, 529 U.S. 362 (2000). In Williams, the United States Supreme Court specifically held that Virginia’s IAC rule violated the United States Supreme Court’s clearly established IAC rules. Reid argued in his federal habeas petition that because the Virginia Supreme Court was silent as to its reasoning for denying the IAC claim, the federal court must presume that it applied the incorrect IAC standard. The federal district court denied Reid’s habeas petition, and Reid appealed to the United States Court of Appeals for the Fourth Circuit.
Rule of Law
Issue
Holding and Reasoning (Wilkins, C.J.)
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