Leif Taylor v. Thomas M. Maddox, Interim Director George Galaza Cal Terhune
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Taylor's distinct § 2254(d)(2) rules for record-based and materially defective-process challenges remain widely applied. One Eleventh Circuit opinion separately declined to follow Taylor's limitation of § 2254(e)(1), while the other reviewed opinions applied the surviving rules or merely reported the Pinholster/Murray history.
789 later cases cite Leif Taylor v. Thomas M. Maddox, Interim Director George Galaza Cal Terhune; 133 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Leif Taylor v. Thomas M. Maddox, Interim Director George Galaza Cal Terhune?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Abrogated
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The Supreme Court foreclosed Taylor's proposed extrinsic-evidence step by limiting AEDPA merits review to the record before the state court; the Ninth Circuit recognized that consequence in Murray v. Schriro.
Cullen v. Pinholster · Supreme Court of the United States · filed
We now hold that review under § 2254(d)(1) is limited to the record that was before the state court that adjudicated the claim on the merits.
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Declined to follow
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The Eleventh Circuit applied contrary circuit law and declined Taylor's rule that § 2254(e)(1)'s clear-and-convincing presumption is limited to challenges presenting new federal-court evidence.
Stinski v. Warden, Georgia Diagnostic Prison · Eleventh Circuit · filed
But we rejected the Ninth Circuit’s approach in Pye, where we articulated and applied a contrary standard.
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