The following excerpt is from Harris v. Carey, No. CIV S-08-CV-2333 CHS (E.D. Cal. 2011):
Third, the "contrary to" and "unreasonable application" clauses of 2254(d)(1) have "independent meanings." Bell v. Cone, 535 U.S. 685, 694 (2002). Under the "contrary to" clause,
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