⚖ Oral Arguments, with Context

Scott Lyles seeks further federal review of his California murder conviction. His defense at trial was that he acted in self-defense. An eyewitness, Bruno, had testified at a preliminary hearing, but the jury did not hear that testimony. Lyles contends that it could have corroborated his defense and that his lawyer was constitutionally ineffective for not presenting it. The issue is the earlier testimony, which could have been read from a transcript, not simply whether the witness should have appeared in person. Michael Drake will seek further proceedings on that claim, including an evidentiary hearing where a court can receive testimony and other evidence. Federal habeas corpus is a challenge to the legality of custody, not another trial of the original charge. Under Strickland, an ineffective-assistance claim generally requires both objectively unreasonable lawyer performance and prejudice: a reasonable probability of a different result, sufficient to undermine confidence in the outcome. An unsuccessful defense alone does not establish either. The procedural sequence is crucial. A state trial court rejected the claim because it considered the showing of prejudice speculative. The state appeals court denied relief without explanation. One California Supreme Court denial cited Duvall's requirement for supporting documents. Lyles resubmitted his petition with Bruno's transcript; that court again denied it without giving reasons. The look-through doctrine ordinarily presumes that an unexplained decision adopted the relevant reasoning of an earlier state decision, but that presumption can be rebutted. Here, the parties disagree about which decision supplies that reasoning and the effect of the intervening document-related denial. You will hear A E D P A, the federal law limiting habeas review. For claims decided on the merits in state court, section twenty-two fifty-four D requires more than a federal judge's disagreement with the result. De novo means fresh review instead of that deference. Which standard applies to which part of Lyles's claim may determine whether further fact-finding is available.

Lyles v. Sherman (No. 25-2969) — U.S. Court of Appeals for the Ninth Circuit, argued October 23, 2026.