AEDPA Deference and the Undeveloped State Factual Record: Monroe v. Angelone and New Evidence

In federal district court, Monroe also alleged ineffective assistance of trial counsel and challenged the sufficiency of the evidence against her.She based her ineffective assistance of counsel claim on trial counsel's failure to challenge the voluntariness of her statements to a detective during the investigation of the murder.See Monroe v. Angelone, No. 3:98CV254, 2002 U.S. Dist.LEXIS 26310, at *86-89 (E.D. Va.Mar. 28, 2002).She eventually dropped the ineffective assistance of counsel claim.Following the disposition of her habeas claim in federal district court, the Court of Appeals for the Fourth Circuit declined to hear the sufficiency of the evidence claim, finding "the district court's resolution of this claim is not 'debatable amongst jurists of reason."Monroe, 323 F.3d at 290 n.2.4.