Fowler

MEMORANDUM **

Bobby Fowler (“Fowler”) appeals from the district court’s denial of his petition for writ of habeas corpus pursuant to 28 U.S.C. § 2254 . Fowler argues that his trial counsel’s failure to object to the admission of a sexually explicit letter constituted ineffective assistance of counsel. Because the facts of the case are known to the parties, we do not recite them here except as necessary to explain our decision.

*715 Under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), a federal court may not grant a habeas petition regarding any claim “adjudicated on the merits” in a state court, unless the state court decision “was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court,” or “was 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)(1) and (2). Further, “a determination of a factual issue made by a State court shall be presumed to be correct.” Id. § 2254(e)(1).

“To establish a claim for constitutionally ineffective assistance of counsel, [a petitioner] must show that counsel made errors so…