The Ninth Circuit Court of Appeals once again granted relief in Steven James v. Ryan. The Court had previously found that Mr. James was denied constitutionally effective counsel at sentencing. After the James opinion, the Supreme Court decided Johnson v. Williams, which creates a rebuttable presumption that the state court adjudicated a claim on the merits. The Supreme Court remanded Mr. James’s case back to the Ninth Circuit to reconsider in light of Johnson.
Applying the presumption, the Ninth Circuit concluded, once again, that the state court had not adjudicated Mr. James’s claim on the merits, but had instead denied relief on procedural grounds.
