Ayala v. Alves, No. 22-1924 (1st Cir. 2023)
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The First Circuit vacated the judgment of the district court granting Plaintiff's petition for a federal writ of habeas corpus on his claim that his state court trial counsel was ineffective, holding that the district court erred in applying the standard set forth under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), Pub. L. No. 104-132, 110 Stat. 1214.
After a jury trial, Petitioner was convicted of first-degree murder, unlawful possession of a firearm, and unlawful possession of ammunition. The Massachusetts Supreme Judicial Court (SJC) affirmed Petitioner's conviction and the trial court's denial of his motion for a new trial. Petitioner subsequently filed a petition for a federal writ of habeas corpus, arguing that his state court trial counsel was ineffective. The federal district court granted the petition. The First Circuit vacated the district court's judgment, holding (1) Petitioner did not meet his burden to show that the SJC's factual determinations were unreasonable, regardless of which standard applied; and (2) the SJC's decision was not an unreasonable application of the law.
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