Stirling v. Stokes

Issues: (1) Whether the U.S. Court of Appeals for the 4th Circuit defied this court’s remand instruction and circumvented 28 U.S.C. § 2254(e)(2)’s limitations on federal-court authority by finding forfeiture based on the state not having offered the statutory argument as an alternative ground to deny relief on the claim when the state was defending on appeal the district court’s sole finding of default; and (2) whether, if the state did forfeit its argument, the 4th Circuit erred in granting relief on a defaulted ineffective-assistance-of-trial-counsel claim by violating basic principles of Strickland v. Washington that require reviewing courts to afford deference to reasonable strategy and that the whole of the evidence be considered in a prejudice analysis.