Full Opinion

USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 1 of 41 FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-11986 ____________________ GEORGE MARTIN, Petitioner-Appellant, versus COMMISSIONER, ALABAMA DEPARTMENT OF CORRECTIONS, Respondent-Appellee. ____________________ Appeal from the United States District Court for the Southern District of Alabama D.C. Docket No. 1:21-cv-00460-TFM-MU ____________________ Before JORDAN, JILL PRYOR, and KIDD, Circuit Judges. USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 2 of 41 2 Opinion of the Court 24-11986 KIDD, Circuit Judge: The State of Alabama committed prosecutorial misconduct in the first trial of George Martin, a former Alabama State Trooper who was accused of killing his wife for pecuniary gain. Because of this misconduct, the state had to try Martin a second time. But at the second trial, the trial judge precluded Martin from raising cer- tain issues concerning the prosecutorial misconduct in the first trial. Martin has now filed a federal habeas corpus petition to chal- lenge his conviction from the second trial. The district court denied Martin’s petition, and he has now appealed the denial to us. On appeal, Martin claims that the state trial court’s preclu- sion order violated the rights guaranteed to him by the Constitu- tion’s Confrontation Clause and prevented him from presenting a complete defense. He also argues that the state presented insuffi- cient evidence for the jury to find that he murdered his wife for pecuniary gain, which was the aggravating factor necessary to im- pose the sentence of life without parole. Alabama’s misconduct in Martin’s case was egregious, and the state courts found as much. But our habeas corpus review is limited by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. § 2254. Those limitations constrain us to affirm the district court’s denial of habeas relief. I. BACKGROUND Because this habeas case arises from a lengthy and complex procedural history spanning two trials almost two decades apart, our discussion of that history is divided into five parts. First, we USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 3 of 41 24-11986 Opinion of the Court 3 discuss the evidence presented during Martin’s first trial and the di- rect appeal of his first conviction. Second, we discuss the collateral proceedings that revealed the state committed prosecutorial mis- conduct before Martin’s trial, which led the trial court to grant Mar- tin a second trial. Third, we discuss the direct appeal proceedings that led to Martin being granted a second trial. Fourth, we discuss the preclusion order entered and the murder-for-pecuniary-gain ev- idence presented during Martin’s second trial, as well as the direct appeal of his second conviction. Finally, we discuss the facts regard- ing the federal habeas proceedings below. A. First Trial and Direct Appeal On October 8, 1995, around 11:30 p.m., law enforcement and emergency responders discovered a black 1991 Ford Escort that had collided with a tree and was on fire on the side of a road in Tillman’s Corner, Alabama. Inside the vehicle was the body of Hammoleketh Martin, George Martin’s wife. At the time of his wife’s death, Martin was an Alabama State Trooper. The Mobile County District Attorney’s Office investi- gated Martin for his wife’s death but ultimately decided not to pros- ecute him after failing to obtain a grand jury indictment. Alabama Attorney General’s Office then initiated another investigation and, four years later, obtained a grand jury indictment. In June 1999, Martin was indicted and charged with capital murder done for a pecuniary or other valuable consideration, in violation of Alabama Code § 13A-5-40(a)(7). The state’s initial the- ory was that Martin deliberately set his wife’s car on fire and staged USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 4 of 41 4 Opinion of the Court 24-11986 the scene to appear as if a traffic collision had caused the fire. The state further theorized that Martin’s motive for killing his wife was for financial gain—life insurance money. Martin maintained he did not kill his wife. He told investigators that his wife’s gas gauge did not work and she kept a red gas can in the back seat of her car. The state’s case was circumstantial. The state primarily re- lied upon a witness, James Taylor, who testified that two hours be- fore Hammoleketh was discovered, he saw an African American trooper in uniform in his work vehicle parked near where she was found. During closing statements, the state argued the jury should conclude that (1) Martin, who is African American, fled the crime scene on a bicycle he planted there earlier; (2) other than Martin’s relatives, no one had ever seen a gas can in his wife’s vehicle; and (3) based on Taylor’s testimony, they should infer that Martin was the trooper Taylor had seen. We recount portions of the state appellate court’s review of the trial evidence to provide context for the years of proceedings that followed, leading to this appeal. A traffic homicide investigator from the Alabama De- partment of Public Safety testified that he examined the vehicle and the scene in question. He conducted speed calculations of a vehicle and analyzed the kind of force that would have been necessary to cause such a fire. He concluded that the fire was not an accident and the collision of the vehicle with a tree did not pro- duce sufficient force to start the fire. .... USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 5 of 41 24-11986 Opinion of the Court 5 The state also introduced evidence of a traffic acci- dent investigation report prepared by Martin approx- imately one year prior to the death of his wife. The report involved a traffic accident in which an automo- bile left the road, hit a tree, and burst into flames. Martin v. State, 931 So. 2d 736, 740–41 (Ala. Crim. App. 2003) (cita- tion modified), aff’d in part, rev’d in part sub nom. Ex parte Martin v. State, 931 So. 2d 736 (Ala. 2004), aff’d on remand, 931 So. 2d 774 (Ala. Crim. App. 2005). The state maintained that Martin staged the ac- cident to look like the prior accident he investigated. See id. at 741. The state also attacked Martin’s credibility. The prosecution argued that Martin was untruthful about whether Hammoleketh carried a gasoline can. See id. at 740. The state further argued that Martin was untruthful about the number of life insurance policies Hammoleketh had. Id. Though Martin acknowledged the exist- ence of a $200,000 policy, the state maintained he lied when he stated there were no other policies. Id. The state introduced evi- dence to support that there was another $150,000 policy that was collectible only if Hammoleketh died in a passenger vehicle. Id. at 740–41. The state connected Martin’s purported need to collect the insurance proceeds by eliciting testimony that his financial condi- tion had worsened to near bankruptcy. Id. at 741. In May 2000, the jury convicted Martin of capital murder for pecuniary gain. Despite the jury’s recommendation by a vote of 8– 4 that he be sentenced to life imprisonment without the possibility of parole, the trial court judge overrode the jury’s recommenda- USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 6 of 41 6 Opinion of the Court 24-11986 tion and sentenced Martin to death. The Alabama Court of Crimi- nal Appeals (“ACCA”) affirmed Martin’s conviction and sentence, and Martin appealed to the Supreme Court of Alabama (“ASC”). The ASC affirmed Martin’s conviction but reversed the trial court’s ruling that overrode the jury’s life-imprisonment recommenda- tion. The ASC then remanded the case to the ACCA with instruc- tions to remand it to the trial court to reconsider its ruling based on new precedent. The trial court did so and resentenced Martin to death, and the ACCA upheld that ruling on appeal. B. Postconviction Proceedings and Brady Violations In 2006, Martin filed a petition for postconviction relief pur- suant to Alabama Rule of Criminal Procedure 32. Specifically, Rule 32.1 permits a petitioner convicted of a criminal offense, and who has exhausted the direct appeals, to file a petition to seek relief on certain enumerated grounds in the court of original conviction. Ala. R. Crim. P. 32.1, 32.2(a)(1). Two of those grounds are at issue here: (1) if the state or federal constitution requires a new trial, and (2) newly discovered material facts exist that require the court to vacate the conviction or sentence. Ala. R. Crim. P. 32.1(a), (e). Prior to Martin’s trial, the judge entered an open file discovery order. During the course of that proceeding, Martin discovered that the state failed to disclose several pieces of material evidence that were favorable to his defense in violation of Brady v. Maryland, 373 U.S. USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 7 of 41 24-11986 Opinion of the Court 7 83 (1963). From 2006 until 2011, Martin litigated for access to the state’s file. In 2009, the trial court ordered the state to provide Mar- tin with all documents in its file. The ACCA and then the ASC de- nied the state’s petitions for a writ of mandamus challenging the court’s order. Then, in 2011, the trial court conducted an in camera inspection of the state’s file and ordered the state to produce all materials except those it deemed privileged. In 2012, the court held a fifteen-day evidentiary hearing that included testimony from 28 witnesses and the introduction of 104 exhibits. After the hearing, the court concluded that the prosecu- tion had failed to disclose four pieces of evidence that were favora- ble to Martin’s defense in violation of Brady. We discuss each before turning to the proceedings that followed the court granting Mar- tin’s petition for a new trial based on those violations. 1. Taylor Implicated Another Suspect During the trial, the prosecution never asked Taylor to iden- tify Martin as the trooper he saw, and there was no evidence pre- sented concerning the size of the trooper Taylor saw. After receiv- ing the state’s file, Martin discovered for the first time that Major Thomas Calhoun of the Mobile Police Department interviewed Taylor twice, in April and May 1997, and Taylor provided Calhoun with evidence that was favorable to Martin’s defense. At the Rule 32 hearing, Calhoun testified he was responsible for deciding what materials would be turned over to Martin’s defense. The court found most of Calhoun’s testimony about his discovery-handling USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 8 of 41 8 Opinion of the Court 24-11986 practices not credible. During the April 1997 interview, Calhoun wrote in his notes that Taylor told him the trooper he saw was a “large black man.” For trial, he typed a summary of this interview. A portion of the summary was read to the jury, but the summary was never marked for identification or introduced as an exhibit. Critically, the sum- mary omitted Taylor’s statement regarding the size of the trooper he saw. And Calhoun’s original notes from the interview were never turned over to the defense or used by the state at trial. Based on its observations, the court determined Martin “[was] not a large man” because he was five feet, six inches tall. During his May 1997 interview, Taylor was shown a photo- graphic array containing thirteen African American troopers, in- cluding Martin. Taylor identified another trooper, Grayling Wil- liams, as the one he had seen the night of the murder. The court credited Martin’s defense counsel’s testimony that the state never turned over Taylor’s identification of Williams. Additionally, Cal- houn wrote in his notes that Taylor similarly relayed that the trooper he saw was a “big man that filled up the car.” The state did not dispute that this note was never turned over to the defense. The court observed that Williams seemed to match Taylor’s de- scriptions because he was five feet, eleven inches tall and weighed 198 pounds in 1995. Without Taylor’s testimony, the state had no witness or other evidence to place Martin at the scene. Notably, Calhoun was present in court during Martin’s trial when the state argued that USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 9 of 41 24-11986 Opinion of the Court 9 the jury could infer from Taylor’s testimony that Martin was the man Taylor saw at the scene. 2. Anonymous Calls Implicating Other Suspects The state also withheld two anonymous calls implicating other suspects. The first call was placed to the Alabama Depart- ment of Public Safety in October 1995. The caller indicated that Hammoleketh was “running around with two white troopers” in a nearby county when Martin was at work. The second call was placed to the Mobile Police Department in November 1995. Nota- bly, the caller indicated that Williams was involved in Hammole- keth’s death. At the Rule 32 hearing, the court credited Martin’s defense counsel’s testimony that he never received information about these calls. 3. Norma Broach Implicated Another Suspect At the hearing, Norma Broach testified that she was at a nearby gas station on the night of Hammoleketh’s death. Broach said that she saw a “white camper truck” and a small black car that matched the description of Hammoleketh’s vehicle parked along the highway not far from where Hammoleketh was found. Accord- ing to Broach, a white man drove the truck to the gas station, went inside the station, filled up two gas cans, and then drove back and parked next to the black car. She then saw the man drag and push “a heavy object” into the passenger side of the truck cab before he sped off toward the area where Hammoleketh was found. The next day, when Broach saw on the news that a woman’s body had been found in a burned-out car near the gas station, she USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 10 of 41 10 Opinion of the Court 24-11986 called the Crimestoppers hotline to relay what she had seen the day prior. Broach reported what she had seen to two Mobile Police De- partment investigators, and also to Williams. Otherwise, law en- forcement did not contact her. Broach was not a witness at Martin’s trial. She continued contacting law enforcement for years about what she had witnessed. The officers who testified at the hearing were uncertain about when they learned of Broach. But a handwritten note from another officer dated October 22, 1995, was admitted as an exhibit, which stated that Broach was at the gas station one hour before Hammoleketh was found and saw a man enter and buy gas. The court determined a jury could find Broach’s testimony credible. And it was undisputed at the hearing that Broach’s identity, her statements, and the October 22, 1995, note were never turned over to Martin’s defense counsel. 4. Gas Can Evidence During the trial, the prosecution told the jury that Martin was not credible when he told officers that his wife carried a gas can in her car because (1) only Martin’s relatives and none of his wife’s friends saw her carry a gas can, and (2) the arson investiga- tors did not find remnants of a gas can at the scene. In May 1997, Calhoun interviewed Hammoleketh’s sister, Terri Jean Jackson. His handwritten notes from the interview re- flected that Jackson stated she saw “a small red plastic gas can” in her sister’s car before the incident. The court determined that the USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 11 of 41 24-11986 Opinion of the Court 11 state never provided this evidence to the defense and thus violated Brady. During Martin’s trial, several firefighters testified that no remnants of a gas can were found. At the Rule 32 hearing, Martin presented evidence that several officers had seen or were aware that remnants of what appeared to be a plastic gas can were recovered from Hammoleketh’s car. Although the court did not find that the state committed a Brady violation, it noted that the state does not contest this information was never disclosed to the defense. C. Martin’s Indictment Dismissed with Prejudice In 2013, the court granted Martin’s Rule 32 petition and ruled that Martin was entitled to a new trial based on the Brady violations. In 2014, the ACCA affirmed the decision, and the ASC denied review on April 17, 2015. On May 7, 2015, the trial court granted Martin’s motion for release pending his new trial. By the time Martin was released, he had been on death row for fifteen years. Martin then moved to dismiss his capital murder indictment with prejudice pursuant to Alabama Rule of Criminal Procedure 16.5. In 2016, the court granted the motion as a sanction after determining that the state’s prosecutorial misconduct was willful and that a new trial would not cure any resulting prejudice to Martin. The court found the state’s misconduct to be willful because Calhoun, aware of Taylor’s prior identification of Williams and de- scription of the trooper, remained silent while prosecutors argued the jury should infer Martin was the trooper Taylor saw. Calhoun USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 12 of 41 12 Opinion of the Court 24-11986 further sat silent when prosecutors argued there was no evidence of the gas can, even though the officer knew that was untrue be- cause Hammoleketh’s sister stated she saw a gas can. The court found that Martin was prejudiced because it had been sixteen years since the trial, twenty years since the event, and many witnesses were deceased or no longer remembered key details. The court also found prejudice because Taylor no longer recalled his previous statements about the other suspect’s size during the Rule 32 hear- ing. The ACCA upheld the dismissal of an indictment as a sanc- tion for prosecutorial misconduct. State v. Martin, 287 So. 3d 355 (Ala. Crim. App. 2017), rev’d sub nom., Ex parte State v. Martin, 287 So. 3d 384 (Ala. 2018). But the ASC reversed and remanded the case to the trial court for a new trial. Martin, 287 So. 3d at 399. The ASC held that neither the death of two unnamed witnesses nor Taylor’s loss of memory established irreparable prejudice to warrant dismis- sal. Id. at 397–99. According to the ASC, Taylor was available to testify, and Martin now had his prior statements with which to im- peach him if necessary. Id. at 398. D. Second Trial and Direct Appeal The judge who presided over the Rule 32 proceedings and dismissed the indictment retired, and a new judge presided over the second trial. USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 13 of 41 24-11986 Opinion of the Court 13 1. Preclusion Order Before trial began, the state filed a motion in limine to ex- clude any mention of prosecutorial misconduct, discovery viola- tions, or withholding of evidence from questions, inferences, nota- tions, observations, statements, or communications by the defense. Additionally, the state moved to exclude the trial court’s rulings re- garding certain witnesses’ credibility. The state maintained that if the trial court permitted the jury to hear about any of its miscon- duct, it would create “an undue prejudice to which the [s]tate could not reasonably surmount.” Martin filed a motion in limine to prevent the exclusion of such evidence. Martin maintained that evidence of the state’s mis- conduct should not be excluded for several reasons. First, it was centrally relevant to Martin’s defense that he was innocent and on trial a second time nineteen years later because the state’s case was weak and skewed by a flawed investigation, bias, and non-credible initial investigators as evidenced by the numerous Brady violations. Second, he had a Sixth Amendment right to confront the state’s witnesses on these topics. Third, the state should be sanctioned for its misconduct; specifically, Martin argued he would be unable to put on a complete defense because they could not pursue all of the previously buried leads twenty years after Hammoleketh’s death. Fourth, without the ability to introduce evidence of the state’s mis- conduct, the jury would receive a one-sided presentation of the ev- idence that Martin would not be able to overcome. USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 14 of 41 14 Opinion of the Court 24-11986 After holding a hearing on the motions, the trial court en- tered a one-page order granting the state’s motion and denying Martin’s. Specifically, the trial court determined “it would be con- fusing and overly prejudicial to allow [Martin] to attempt to explain the long and complicated procedural history of this case to the jury, and that most, if not all, of this material [wa]s not relevant. For the same reasons, [Martin’s] request for preclusion sanctions, adverse inferences, and jury instructions would be unduly prejudicial.” The day after the court entered the preclusion order, it noted in a telephonic hearing in response to Martin’s motion for clarification that it expected Martin’s defense to get into the state’s failure to pursue leads, alternative theories, alternative suspects, and the state’s allegedly biased conduct. However, the court cau- tioned the defense that these matters could not be introduced through any evidence, cross-examination, or argument concerning the prior trial, the Rule 32 proceedings, the proceedings on the mo- tion for a new trial, or the motion to dismiss the indictment. The court emphasized that, despite its best efforts, it could not fashion a jury instruction or a remedy to explain the state’s mis- conduct in the original trial, and doing so would cause confusion and amount to a trial within a trial if the door were opened to ad- dress any of the state’s misconduct. USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 15 of 41 24-11986 Opinion of the Court 15 2. Evidence Presented During Second Trial Taylor, Broach, Williams, and Jackson all testified at the sec- ond trial. During the first trial, one of the arguments the state made to prove that Martin killed his wife for pecuniary gain was that he did not disclose to investigators all the life insurance policies that cov- ered his wife. Specifically, the state maintained that Martin did not disclose a $150,000 policy that was payable only if Hammoleketh died in a passenger vehicle. In its case-in-chief, the state introduced a copy of the policy into evidence through an insurance company witness. During the second trial, the state never admitted a copy of the policy into evidence. And the state withdrew its only witness to prove murder for pecuniary gain and instead maintained at side- bar that “[t]he mere existence of an insurance policy is the only thing that is [relevant] to the [s]tate’s case in chief[.]” The state bore the burden to prove pecuniary gain; nevertheless, in Martin’s case- in-chief, he presented testimony from an accounting expert and life insurance expert to rebut that he murdered his wife for pecuniary gain. They testified that Martin was in good financial health and the amount of life insurance policies Hammoleketh had were nor- mal and did not raise any red flags. But this opened Martin’s wit- nesses to cross-examination by the state, which attacked those con- clusions. On June 7, 2019, the second jury found Martin guilty of cap- ital murder for pecuniary gain, and the court sentenced him to life USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 16 of 41 16 Opinion of the Court 24-11986 imprisonment without the possibility of parole. The trial court de- nied Martin’s request for a new trial or judgment of acquittal. Mar- tin appealed his second conviction to the ACCA. As relevant to this appeal, Martin maintained that the trial court’s preclusion order vi- olated his Confrontation Clause rights and precluded him from presenting a complete defense. He also argued that the state pre- sented insufficient evidence for the jury to determine murder for pecuniary gain, the aggravating factor necessary to sustain the cap- ital murder conviction. The ACCA affirmed Martin’s conviction and denied his request for rehearing, and the ASC summarily de- nied Martin’s petition for certiorari. E. The Federal Habeas Proceedings After the ASC denied review, Martin filed a habeas corpus petition, pursuant to 28 U.S.C. § 2254, in the Southern District of Alabama based on the same three grounds raised in his direct ap- peal. The state did not address the merits of the confrontation and complete defense claims and instead argued they were procedur- ally defaulted. For the sufficiency of the evidence claim, the state conceded that Martin presented it on direct appeal but argued it failed on the merits. The magistrate judge recommended that the district judge deny in part and dismiss in part Martin’s petition and grant him a certificate of appealability for his confrontation and complete de- fense claims, but not his sufficiency of the evidence claim (“COA”). The magistrate judge, sua sponte, concluded that Martin’s suffi- USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 17 of 41 24-11986 Opinion of the Court 17 ciency of the evidence claim was unexhausted and procedurally de- faulted, and declined to address it on the merits. The magistrate judge then determined that Martin’s confrontation and complete defense claims were not procedurally defaulted and failed on the merits. The state objected to the magistrate judge’s determination that Martin’s confrontation and complete defense claims were not procedurally defaulted. Martin objected to the magistrate judge’s determination that AEDPA deference applied to review of his con- frontation and complete defense claims. Alternatively, he main- tained that his confrontation claim and complete defense claims should succeed on the merits under AEDPA deference. He further objected to the magistrate judge’s determination that his suffi- ciency of the evidence claim was procedurally defaulted and main- tained that relief should be granted on the merits, or alternatively that he should be granted a COA on that claim. The district judge adopted the report and recommendation, overruled Martin’s and the state’s objections, and alternatively found that the sufficiency claim failed on the merits. The district court granted Martin a COA and entered final judgment. Martin’s COA specifies these issues: (1) Whether the state waived any exhaustion defense to the sufficiency claim by acknowledging that the claim “was presented on direct appeal” in its response to the petition; USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 18 of 41 18 Opinion of the Court 24-11986 (2) Whether Martin exhausted his sufficiency claim in state court by bringing state law claims based on the same “reasonable doubt” standard applicable to fed- eral claims; (3) Whether, if the sufficiency claim was exhausted, the Alabama courts’ conclusion that the state suffi- ciently proved that Martin committed murder for pe- cuniary gain was contrary to, or involved an unrea- sonable application of, clearly established federal law or was based on an unreasonable determination of facts in light of the evidence; (4) Whether the Alabama courts’ decision to uphold the preclusion order was contrary to, or involved an unreasonable application of, clearly established fed- eral law as determined by the Supreme Court of the United States, specifically the Confrontation Clause of the Sixth Amendment; (5) Whether the Alabama courts’ decision to uphold the preclusion order was contrary to, or involved an unreasonable application of, clearly established Fed- eral law as determined by the Supreme Court of the United States, specifically the Sixth and Fourteenth Amendments of the Constitution and the ensuing right to present a complete defense. Doc. 40 at 1–2 (citation modified). USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 19 of 41 24-11986 Opinion of the Court 19 II. STANDARD OF REVIEW “We review a court’s decision to deny a § 2254 petition de novo, applying a de novo standard to legal conclusions and a clear error standard to factual findings.” Carruth v. Comm’r, Ala. Dep’t of Corr., 93 F.4th 1338, 1352 (11th Cir.), cert. denied, 145 S. Ct. 208 (2024). If “a claim is properly presented to the state court, but the state court does not adjudicate it on the merits, we review de novo.” Mason v. Allen, 605 F.3d 1114, 1119 (11th Cir. 2010) (emphasis omitted). But when a state court adjudicates a petitioner’s claim on the merits, AEDPA further governs our review. AEDPA prohibits relief unless the state court’s decision was (1) “contrary to, or in- volved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States,” 28 U.S.C. § 2254(d)(1); or (2) “based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding,” 28 U.S.C. § 2254(d)(2). “If a state court unreasonably applied federal law or unreasonably determined the facts in a case, we review the underlying claim de novo.” King v. Warden, Ga. Diag- nostic Prison, 69 F.4th 856, 867 (11th Cir. 2023) (emphasis omitted). Under 28 U.S.C. § 2254(d)(1), a state court’s decision is “con- trary to . . . clearly established Federal law” when it “appl[ies] a rule that contradicts the governing law set forth by Supreme Court case law,” or when it “reach[es] a different result from the Supreme Court when faced with materially indistinguishable facts.” Davis v. USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 20 of 41 20 Opinion of the Court 24-11986 Comm’r, Ala. Dep’t of Corr., 120 F.4th 768, 788 (11th Cir. 2024) (cita- tion modified), petition for cert. filed, No. 25-1410 (U.S. June 18, 2026). An “unreasonable application of . . . clearly established Fed- eral law,” 28 U.S.C. § 2254(d)(1), occurs when “the state court cor- rectly identifies the governing legal principle . . . but unreasonably applies it to the facts of the particular case.” Davis, 120 F.4th at 788 (citation modified). “A state court unreasonably applies federal law only if no fairminded jurist could agree with the state court’s de- termination or conclusion.” King, 69 F.4th at 867 (citation modi- fied). For our review of habeas corpus petitions filed pursuant to 28 U.S.C. § 2254(d)(2), “a state court’s factual determinations are ‘presumed to be correct,’” and that presumption can be overcome only “by clear and convincing evidence.” Pye v. Warden, Ga. Diag- nostic Prison, 50 F.4th 1025, 1035 (11th Cir. 2022) (en banc) (quoting 28 U.S.C. § 2254(e)(1)). Still, “[e]ven if the state court made a clearly erroneous factual determination, that doesn’t necessarily mean the state court’s ‘decision’ was ‘based on’ an ‘unreasonable determina- tion of the facts in light of the evidence presented in the State court proceeding.’” Id. (quoting 28 U.S.C. § 2254(d)(2)). “Depending on the importance of the factual error to the state court’s ultimate ‘de- cision,’ that decision might still be reasonable even if some of the state court’s individual factual findings were erroneous—so long as the decision, taken as a whole, doesn’t constitute an ‘unreasonable determination of the facts’ and isn’t ‘based on’ any such determi- nation.” Id. (citation modified). USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 21 of 41 24-11986 Opinion of the Court 21 III. DISCUSSION We begin our discussion by examining whether Martin’s claims were procedurally defaulted. Finding no default, we next ex- plain why Martin’s confrontation claim is not subject to AEDPA deference but still fails under our de novo review. Then, we discuss why AEDPA deference applies to Martin’s complete defense claim and why it fails under that standard. Finally, we explain why Mar- tin’s sufficiency of the evidence claim fails under AEDPA. A. Procedural Default On appeal, the state argues that Martin has procedurally de- faulted all three of his claims. Martin maintains he did not proce- durally default his claims because he exhausted them by raising them throughout his state court proceedings. “Habeas petitioners generally cannot raise claims in federal court that were not first exhausted in state court.” Kelley v. Sec’y, Fla. Dep’t of Corr., 377 F.3d 1317, 1343 (11th Cir. 2004). Whether a peti- tioner exhausted a claim presents a mixed question of law and fact, subject to our de novo review. See Fox v. Kelso, 911 F.2d 563, 568 (11th Cir. 1990). “To properly exhaust a claim, the petitioner must afford the State a full and fair opportunity to address and resolve the claim on the merits.” Kelley, 377 F.3d at 1343 (citation modified). The exhaustion requirement is not satisfied if the petitioner (1) fails to raise a federal claim in the state court, see Bailey v. Nagle, 172 F.3d 1299, 1303 (11th Cir. 1999), or (2) fails to raise a claim in terms of federal law, Jimenez v. Fla. Dep’t of Corr., 481 F.3d 1337, 1342 (11th Cir. 2007). A petitioner is not required, however, to give “a USCA11 Case: 24-11986 Document: 66-1 Date Filed: 09/14/2026 Page: 22 of 41 22 Opinion of the Court 24-11986 separate federal law heading to each of the c