CA11: State court allegedly applying wrong standard isn’t denial of “full and fair opportunity to litigate” in state court

Just because the state court is alleged to be wrong and applied the wrong standard, that doesn’t make the defendant was denied a full and fair opportunity to litigate in state court under Stone v. Powell. Sheffield v. Sec’y, Dep’t of Corr., 2016 U.S. App. LEXIS 23861 (11th Cir. Dec. 14, 2016) (order):

In this case, reasonable jurists would not debate the district court’s conclusion that this claim was barred from federal habeas review by Stone. Contrary to Sheffield’s claim, Sheffield was not deprived of a full and fair opportunity to litigate this claim in state court. Specifically, the record reveals that he was given an evidentiary hearing, the state trial court made explicit findings on matters essential to the Fourth Amendment issue, and meaningful appellate review was available in the state appellate court. Tukes, 911 F.2d at 513-14; see also Bradley, 212 F.3d at 565. Further, there is no indication that the state court’s determination that the officers had probable cause to search Sheffield’s vehicle was based on an erroneous factor. In light of the above, the district court properly determined that this claim was barred from federal habeas review. Stone, 428 U.S. at 494.