“The Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) requires a prisoner who challenges (in a federal habeas court) a matter ‘adjudicated on the merits in State court’ to show that the relevant state-court ‘decision’ (1) ‘was contrary to, or involved an unreasonable application of, clearly established Federal law,’ or (2) ‘was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.’” Wilson v Sellers, 584 US ___, ___ (2018), quoting 28 USC 2254(d). “Deciding whether a state court’s decision ‘involved’ an unreasonable application of federal law or ‘was based on’ an unreasonable determination of fact requires the federal habeas court to ‘train its attention on the particular reasons-both legal and factual-why state courts rejected a state prisoner’s federal claims,’ and to give appropriate deference to that decision[.]” Wilson, 584 US at ___ (citations omitted). “A state court’s determination that a claim lacks merit precludes federal habeas relief so long as ‘fairminded jurists could disagree’ on the correctness of the state court’s decision.” Harrington v Richter, 562 US 86, 101 (2011), quoting Yarborough v Alvarado, 541 US 652, 664 (2004).
“Clearly established Federal law for purposes of [28 USC 2254(d)] includes only the holdings, as opposed to the dicta, of [the United States Supreme Court’s] decisions.” White v Woodall, 572 US 415, 419 (2014) (citations and quotations omitted). “And an unreasonable application of those holdings must be objectively unreasonable, not merely wrong; even clear error will not suffice.” Id. (citations and quotations omitted). “As a condition for obtaining habeas corpus from a federal court, a state prisoner must show that the state court’s ruling on the claim being presented in federal court was so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement.” Harrington, 562 US at 103. AEDPA’s requirements reflect a “presumption that state courts know and follow the law.” Woodford v Visciotti, 537 US 19, 24 (2002). “Section 2254(d) reflects the view that habeas corpus is a guard against extreme malfunctions in the state criminal justice systems, not a substitute for ordinary error correction through appeal.” Harrington, 562 US at 102-103 (citation and quotation omitted).