For purposes of 28 U.S.C. § 2254(d), when a state court rules against a defendant in an opinion that rejects some of his claims but does not expressly address a federal claim, a federal habeas court must presume, subject to rebuttal, that the federal claim was adjudicated on the merits.
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U.S. SUPREME COURT
Johnson v. Williams
New Jersey Law Journal
February 20, 2013
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