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Federal Habeas: Procedure — Appellate — Standard of Review — State Court Adjudication on Merits

Allen A. Muth v. Frank, 412 F.3d 808 (7th Cir 2005)

Issue/Holding: AEDPA requirement of state court adjudication on merits requires neither “well-articulated or even correct decision”; state court need not offer any reasons, so that summary disposition would satisfy requirement. In short: it “is perhaps best understood by stating what it is not: it is not the resolution of a claim on procedural grounds.”

Followed: Joseph M. Malinowski v, Smith, 06-3075, 11/27/07 (state court’s rejection of argument solely on basis of discussion of state privilege nonetheless represents adjudication on merits of due process challenge).

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