Nicholas Beaudreaux was convicted of murder after two witnesses identified him as the shooter, including one witness who had viewed two photo arrays and later identified Beaudreaux in person. In a federal habeas proceeding, the Ninth Circuit held that the state court unreasonably rejected Beaudreaux’s claim that trial counsel was ineffective for failing to seek suppression of the identification evidence. The Supreme Court reversed and remanded. Under the Antiterrorism and Effective Death Penalty Act, a federal court reviewing a summary state decision must consider every reasonable argument that could have supported the state court’s result and must apply deference rather than review the claim de novo. The Ninth Circuit instead relied partly on theories Beaudreaux had not presented to the state court and treated the identification issue as though it were being decided in the first instance. The Supreme Court held that the state court could reasonably have rejected the ineffective-assistance claim, particularly under the deferential standard applicable to fact-sensitive questions of suggestiveness and reliability. Justice Breyer dissented.