What happened
The Fourth Circuit reversed a federal district court order granting habeas relief to South Carolina prisoner K.C. Langford, ruling that state courts had reasonably rejected his speedy-trial and ineffective-assistance claims.
Langford was convicted by a South Carolina jury of criminal conspiracy, armed robbery, first-degree burglary and kidnapping. After the South Carolina Supreme Court affirmed his convictions and a state court denied postconviction relief, he sought federal habeas relief, arguing that the state courts had wrongly rejected his speedy-trial challenge and his claim that trial counsel was ineffective.
The federal district court granted the writ on both grounds, but the Fourth Circuit said the lower court failed to apply the deference required by the Antiterrorism and Effective Death Penalty Act. The panel said federal courts owe considerable deference to state-court decisions resolving claims already adjudicated on the merits.
On the speedy-trial issue, the panel noted that the South Carolina Supreme Court applied the Barker v. Wingo framework and that the relevant question in federal court was not whether the Fourth Circuit would weigh the factors the same way, but whether the state court unreasonably applied clearly established Supreme Court law.
The ineffective-assistance claim centered on counsel's failure to object to testimony about an informant's tip that led investigators to Langford and others. The Fourth Circuit said counsel could have reasonably chosen not to object in order to avoid undermining a co-defendant's effort to cast doubt on the investigation, and that fairminded jurists could also disagree over whether excluding the testimony would have changed the verdict.
The panel was sharply critical of the district court's approach, saying it effectively evaluated the merits of the ineffective-assistance issue de novo and then added a conclusion that the state court was unreasonable. Because South Carolina courts adjudicated both claims on the merits and did not unreasonably apply federal law or determine the facts, the Fourth Circuit reversed the habeas grant.