Federal review of a state judgment is narrowly defined
Section 2254 authorizes federal courts to consider an application by a person in custody under a state-court judgment on the ground that custody violates the Constitution, laws, or treaties of the United States. It does not give the federal court general authority to correct every error of state law.
The Antiterrorism and Effective Death Penalty Act created demanding standards for federal review of claims adjudicated by state courts. The precise analysis depends on the claim, the state-court ruling, the factual record, and how the issue was presented through the state system.
Exhaustion requires fair presentation to the state courts
The statute generally requires exhaustion of available state remedies. In practical terms, the federal constitutional nature of the claim must ordinarily be fairly presented through the required levels of state-court review before a federal court will consider it.
A similar factual complaint or state-law argument may not preserve the federal claim. The state petitions, briefs, orders, and discretionary-review filings must be examined to determine what was actually presented.
Procedural default can prevent merits review
If a state court rejected a claim under an adequate and independent state procedural rule, or if state procedures are no longer available because the claim was not properly raised, federal review may be barred absent a recognized basis to overcome the default.
Cause, prejudice, and miscarriage-of-justice doctrines are specialized and fact-dependent. They should not be treated as automatic exceptions.
Build the federal analysis from the state record
A § 2254 review should begin with the trial and sentencing records, direct-appeal briefs and decision, state post-conviction petition, hearing record, post-conviction decisions, and filings seeking higher state-court review. Those materials reveal not only the underlying facts, but also the exact claim adjudicated by each court.
The objective is to map each proposed federal claim to its factual basis, constitutional source, state-court presentation, ruling, and applicable federal standard.