Cook v. Barton

(1) Whether, when a state court's decision on a prisoner's constitutional claim contains both reasoning substantively rejecting the claim and reasoning procedurally rejecting the claim, the Antiterrorism and Effective Death Penalty Act section 2254(d)"s standards apply to the claim; and (2) whether, if a lower court in the state proceedings rejects a state prisoner's claim "on the merits," " 2254(d)"s standards nevertheless fall away whenever a higher court in the state proceedings rejects the claim on procedural grounds without addressing the claim substantively.