This morning, the Supreme Court will hear argument in the capital habeas case of Wood v. Allen. I have previously discussed the case here.
The issue in the case is: "how a federal court should review the facts determined in a state criminal proceeding under the Antiterrorism and Effective Death Penalty Act (AEDPA)."
More specifically, the question in the case concerns the interplay between 2254(d)(2) and 2254(e)(1), which have different standards for reviewing state court factual findings.
The Second Circuit has yet to address this issue. See Green v. Travis, 414 F.3d 288 (2d Cir. 2005) ("This Court has not yet addressed whether a petitioner seeking habeas relief must prevail under both 2254(d)(2) and 2254(e)(1)."). So no matter how the Court decides the issue it will have an impact on the state of the law in the Second Circuit.
For other coverage of Wood v. Allen, see this post at the ACS Blog.