Wilson: On habeas review, court will not "look through" summary disposition

In Wilson v. Warden, No. 14-10681 (Aug. 23, 2016), the Court (en banc) (6-5), affirmed the denial of habeas relief to a Georgia inmate sentenced to death for a 1996 murder. Wilson had sought habeas relief in Georgia state courts unsuccessfully: his request for a certificate of probable cause was summarily denied by the Georgia Supreme Court. The Court held that this adjudication was an adjudication on the merits. The Court would not “look through” this denial to the reasoning of the lower court. Wilson was required to show that there was no reasonable basis for the Georgia Supreme Court’s ruling, which he failed to do.