Sandra Coombs v. State of Maine, 202 F.3d 14 (1st Cir. 2000). · Go Syfert
Sandra Coombs v. State of Maine, 202 F.3d 14 (1st Cir. 2000). Cases Citing This Book View Copy Cite
62 citation events (52 in the last 25 years) across 13 distinct courts.
Strongest positive: Hipschman v. County of San Diego (casd, 2023-09-05)
Treatment trajectory · 2000 → 2026 · click a year to view as-of
2000 2013 2026
Top citers, strongest first. 34 distinct citers.
examined Cited as authority (rule) Hipschman v. County of San Diego (3×) also: Cited "see"
S.D. Cal. · 2023 · confidence medium
The Ninth Circuit reaffirmed this holding in 11 Wallis and specified that “the state may not remove children from their parents’ custody 12 without a court order unless there is specific, articulable evidence that provides reasonable 13 cause to believe that a child is in imminent danger of abuse.” Wallis v. Spencer, 202 F.3d 14 1126, 1138 (9th Cir. 2000).
cited Cited as authority (rule) Gould v. Mitchell
D. Mass. · 2022 · confidence medium
RaShad v. Walsh, 300 F.3d 27, 44 (1st Cir. 2002); Coombs v. Maine, 202 F.3d 14, 18 (1st Cir. 2000).
discussed Cited as authority (rule) Durand v. Goguen
D. Mass. · 2022 · confidence medium
Pursuant to 28 U.S.C. § 2254 (e)(1), “a determination of a factual issue made by a State court shall be presumed to be correct.” This presumption applies to findings of historical, basic or primary facts – “facts in the sense of a recital of external events and the credibility of their narrators.” Coombs v. Maine, 202 F.3d 14, 18 (1st Cir. 2000) (quoting Bryson v. Ward, 187 F.3d 1193, 1211 (10th Cir. 1999)).
discussed Cited as authority (rule) Sanchez-Burgos v. Vega-Aponte
D.P.R. · 2021 · confidence medium
To determine whether an assertion of actual innocence is tenable, a federal court sitting in habeas must accord deference to the state court’s factual findings, which are presumed correct and may only be rebutted by “clear and convincing evidence.” Miller-El v. Dretke, 545 U.S. 231, 240 (2005); Coombs v. State of Maine, 202 F.3d 14, 18 (1st Cir. 2000) (discussing topic).14 13 See also, Keeling v. Warden, 673 F.3d 452, 462-463 (6th Cir. 2012)(equitable tolling not warranted in light of unexcused three-year delay); Neverson, 366 F.3d at 32 (three years of unexplained delay). 14 The presump…
cited Cited as authority (rule) Slaven v. Russo
D. Mass. · 2020 · confidence medium
See, e.g., Gunter v. Maloney, 291 F.3d 74, 76 (1st Cir. 2002); Sanna v. DiPaolo, 265 F.3d 1, 7 (1st Cir. 2001); Coombs v. Maine, 202 F.3d 14, 18 (1st Cir. 2000).
discussed Cited as authority (rule) Fasion v. Jones
E.D. Cal. · 2020 · confidence medium
“The 12 status quo ante litem refers not simply to any situation before the filing of a lawsuit, but instead to 13 the last uncontested status which preceded the pending controversy.” GoTo.com, Inc., 202 F.3d 14 at 1210 (internal quotation marks omitted).
discussed Cited as authority (rule) Santana v. Cowen (2×) also: Cited "see, e.g."
D. Mass. · 2019 · confidence medium
A “factual issue” may consist of “basic, primary, or historical facts: facts in the sense of a recital of external events and the credibility of their narrators.” Coombs v. Maine, 202 F.3d 14, 18 (1st Cir. 2000) (internal citations and quotations omitted).
discussed Cited as authority (rule) Bly v. St. Amand
D. Mass. · 2014 · confidence medium
The court must presume that the state court’s factual determinations are correct unless the petitioner rebuts this “presumption of correctness” with “clear and convincing evidence.” 28 U.S.C. § 2254 (e)(1); Coombs v. Maine, 202 F.3d 14, 18 (1st Cir.2000); DeBurgo, 587 F.3d at 62 .
examined Cited as authority (rule) Ervin v. Commonwealth (4×)
Va. Ct. App. · 2011 · confidence medium
Hill v. Commonwealth, 52 Va.App. 313, 317, 663 S.E.2d 133, 135 (2008); Commonwealth v. Thomas, 23 Va.App. 598, 603 , 478 S.E.2d 715, 717 (1996); United States v. Wheeler, 525 F.3d 1254, 1255 (D.C.Cir.2008); Coombs v. Maine, 202 F.3d 14, 15 (1st Cir.2000); United States v. Schiavo, 29 F.3d 6, 8 (1st Cir.1994), even in instances, like here, where the vehicle is not actually owned by the suspect, see Williams, 42 Va.App. at 728 , 594 S.E.2d at 308 ; United States v. Reese, 561 F.2d 894, 897 (1st Cir.1975); Scott v. United States, 369 F.2d 183, 184 (4th Cir.1966).
discussed Cited as authority (rule) Rivera v. Nolan
D. Mass. · 2009 · confidence medium
See also Thompson v. Keohane, 516 U.S. 99, 111 , 116 S.Ct. 457 , 133 L.Ed.2d 383 (1995) (interpreting pre-AEDPA revision of habeas statute, and noting that the Supreme Court has classified as “factual issues” those whose “resolution depends heavily on the trial court’s appraisal of witness credibility and demean- or”); Coombs v. State of Maine, 202 F.3d 14, 18 (1st Cir.2000) (“ ‘factual issues’ are defined as basic, primary, or historical facts: facts in the sense of a recital of external events and the credibility of their narrators”) (internal quotations and citation omitte…
discussed Cited as authority (rule) Teti v. Bender
1st Cir. · 2007 · signal: cf. · confidence medium
See, e.g., Blackwell, 387 F.3d at 235 (“[Section] 2254(d)(2)’s reasonableness determination turns on a consideration of the totality of the ‘evidence presented in the state-court proceeding,’ while § 2254(e)(1) contemplates a challenge to the state court’s individual factual determinations .... ” (quoting 28 U.S.C. § 2254 (d)(2))); Valdez, 274 F.3d at 951 n. 17; cf. Coombs v. State of Maine, 202 F.3d 14, 18 (1st Cir.2000) (suggesting but not explicating this distinction).
cited Cited as authority (rule) Knight v. Spencer
1st Cir. · 2006 · confidence medium
See Gunter v. Maloney, 291 F.3d 74, 76 (1st Cir.2002); Coombs v. State of Maine, 202 F.3d 14, 18 (1st Cir.2000).
discussed Cited as authority (rule) Healy v. Spencer (2×)
D. Mass. · 2005 · confidence medium
In support of this position, the Commonwealth cites a litany of cases holding that state court factual findings are presumptively correct and that this presumption extends to factual determinations made by appellate courts, as well as factual findings implicit in state court rulings, including: Parke v. Raley, 506 U.S. 20, 35 , 113 S.Ct. 517 , 121 L.Ed.2d 391 (1992); Rashad v. Walsh, 300 F.3d 27, 35 (1st Cir.2002), cert. denied, 537 U.S. 1236 , 123 S.Ct. 1360 , 155 L.Ed.2d 202 (2003); Gunter v. Maloney, 291 F.3d 74, 76 (1st Cir.2002); Sanna v. Dipaolo, 265 F.3d 1, 7 (1st Cir.2001); Coombs v. M…
cited Cited as authority (rule) Simpson v. Spencer
D. Mass. · 2005 · confidence medium
See Gunter v. Maloney, 291 F.3d 74, 76 (1st Cir.2002); Sanna v. Dipaolo, 265 F.3d 1, 7 (1st Cir.2001); Coombs v. Maine, 202 F.3d 14, 18 (1st Cir.2000).
discussed Cited as authority (rule) Colin v. Lampert
D. Or. · 2002 · confidence medium
“Factual issues” are defined as “basic, primary, or historical facts: facts in the sense of a recital of external events and the credibility of their narrators.” Coombs v. Maine, 202 F.3d 14, 18 (1st Cir.2000) (citations and internal quotation marks omitted).
discussed Cited as authority (rule) Rashad v. Walsh
D. Mass. · 2002 · confidence medium
See also, e.g., Thompson v. Keohane, 516 U.S. 99, 107-09 , 116 S.Ct. 457 , 133 L.Ed.2d 383 (1995) (interpreting pre-AEDPA version of statute); Coombs v. Maine, 202 F.3d 14, 18 (1st Cir.2000); Pettiway v. Vose, 100 F.3d 198, 202-03 (1st Cir.1996) (holding that, on habeas corpus review, findings of fact by the state court are to be overturned only if the federal court concludes that such factual determination is not fairly supported by the record).
discussed Cited as authority (rule) Martinez v. Spencer
D. Mass. · 2002 · confidence medium
“For this purpose, factual issues are defined as basic, primary, or historical facts: facts in the sense of a recital of external events and the credibility of their narrators.” Coombs v. State of Maine, 202 F.3d 14, 18 (1st Cir.2000); accord Sanna v. Dipaolo, 265 F.3d 1, 7 (1st Cir.2001).
discussed Cited as authority (rule) Niland v. Hall
1st Cir. · 2002 · confidence medium
Furthermore, under the AEDPA, state-court determinations of factual issues “shall be presumed to be correct,” unless the petitioner rebuts the presumption “by clear and convincing evidence.” 28 U.S.C. § 2254 (e)(1); Coombs v. Maine, 202 F.3d 14, 18 (1st Cir.2000).
cited Cited as authority (rule) DiBenedetto v. Hall
1st Cir. · 2001 · confidence medium
Coombs v. Maine, 202 F.3d 14, 18 (1st Cir.2000).
examined Cited as authority (rule) DiBenedetto v. Hall (3×) also: Cited "see, e.g."
D. Mass. · 2000 · confidence medium
Under AEDPA, when a federal court reviews a state court’s legal determinations, including “mixed questions of law and fact in which legal principles are applied to historical facts,” Coombs v. State of Maine, 202 F.3d 14, 18 (1st Cir.2000), habeas relief is to be granted only where the state court’s adjudication (1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States; or (2) resulted in a decision that was based on an unreasonable determination of the facts in l…
discussed Cited as authority (rule) Ballinger v. Byron
D. Mass. · 2000 · confidence medium
Under AEDPA, when a federal court reviews a state court’s legal determinations, including “mixed questions of law and fact in which legal principles are applied to historical facts,” Coombs v. State of Maine, 202 F.3d 14, 18 (1st Cir.2000), habeas relief is to be granted only where the state court’s adjudication (1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States; or (2) resulted in a decision that was based on an unreasonable determination of the facts in l…
discussed Cited as authority (rule) Edwards v. Murphy
D. Mass. · 2000 · confidence medium
As the Court of Appeals for the First Circuit has recently stated, “[f|or this purpose, factual. issues are defined as basic, primary, or historical facts: facts in the sense of a recital of external events and the credibility of their narrators.” Coombs v. State of Maine, 202 F.3d 14, 18 (2000) (internal quotations and citations omitted).
cited Cited "see" Donaldo Galaz v. People of The State of California
C.D. Cal. · 2024 · signal: see · confidence high
See Park v. California, 202 F.3d 14 1146 (9th Cir. 2000).
discussed Cited "see" Sok v. Spencer (2×)
D. Mass. · 2008 · signal: see · confidence high
See Coombs v. State of Maine, 202 F.3d 14, 18 (1st Cir.2000) (“Such a state court finding of ‘basic, primary, or historical facts’ based on a credibility determination is ‘presumed to be correct,’ subject only to rebuttal by ‘clear and convincing evidence.’ ”) (quoting 28 U.S.C. § 2254 (e)(1)).
cited Cited "see" United States Ex Rel. Hinton v. Snyder
N.D. Ill. · 2002 · signal: see · confidence high
See Coombs v. Maine, 202 F.3d 14, 18 (1st Cir.2000).
discussed Cited "see" McCambridge v. Hall (2×) also: Cited "see, e.g."
D. Mass. · 2000 · signal: see · confidence high
See Coombs, 202 F.3d at 18 .
cited Cited "see, e.g." Santana v. Cowen
D.D.C. · 2019 · signal: compare · confidence low
Compare Sanna , 265 F.3d at 7 with Coombs , 202 F.3d at 18 .
discussed Cited "see, e.g." Scoggins v. Hall
1st Cir. · 2014 · signal: see also · confidence medium
Additionally, to the extent that Scoggins’s constitutional arguments depend on factual premises the state court rejected, we are required by statute to “presume[ ] ... correct” the state court’s factual determinations, leaving to Scoggins the weighty “burden of rebutting the presumption of correctness by clear and convincing evidence.” See 28 U.S.C. § 2254 (e)(1); see also Coombs v. Maine, 202 F.3d 14, 18 (1st Cir.2000).
discussed Cited "see, e.g." McCONKIE v. Nichols
D. Me. · 2005 · signal: see also · confidence medium
See also Coombs v. Maine, *13 202 F.3d 14, 19 (1st Cir.2000)(“it is less apparent to us than to the Maine Law Court that if a promise had been made it automatically would have rendered the confession involuntary”).
discussed Cited "see, e.g." Smiley v. Maloney
1st Cir. · 2005 · signal: see, e.g. · confidence medium
See, e.g., Coombs v. Maine, 202 F.3d 14, 18 (1st Cir.2000); cf. Sumner v. Mata, 449 U.S. 539, 545-47 , 101 S.Ct. 764 , 66 L.Ed.2d 722 (1981) (presumption of correctness under former habeas statute applied to "factual determinations made by state courts, whether the court be a trial court or appellate court"). 2 .
cited Cited "see, e.g." Olszewski v. Spencer
D. Mass. · 2005 · signal: see also · confidence medium
See also Coombs v. Maine, 202 F.3d 14, 18 (1st Cir.2000). 2 .
discussed Cited "see, e.g." Gaines v. Matesanz
D. Mass. · 2003 · signal: see also · confidence medium
Underlying Facts The following facts, taken from the SJC’s decision in Commonwealth v. Funderberg, are entitled to a presumption of correctness. 28 U.S.C. § 2254 (e)(1); see also Coombs v. Maine, 202 F.3d 14, 18 (1st Cir.2000).
discussed Cited "see, e.g." United States v. Adams
D. Me. · 2002 · signal: see, e.g. · confidence medium
See, e.g., Coombs v. State of Maine, 202 F.3d 14, 19 (1st Cir.2000) (noting, in habeas case, that “it is less apparent to us than to the Maine Law Court that if a promise had been made it automatically would have rendered the confession involuntary”); United States v. Byram, 145 F.3d 405, 408 (1st Cir.1998) (“[I]t would be very hard to treat as coercion a false assurance to a suspect that he was not in danger of prosecution.”) (emphasis in original).
discussed Cited "see, e.g." Sanna v. DiPaulo (2×)
1st Cir. · 2001 · signal: see also · confidence medium
It is worth noting, however, that these words cannot be read in a vacuum; they must be interpreted in conjunction with a companion subsection specifying that “a determination of a factual issue made by a State court shall be presumed to be correct,” and that “[t]he applicant shall have the burden of rebutting the presumption of correctness by clear and convincing evidence.” Id. § 2254(e)(1); see also Coombs v. Maine, 202 F.3d 14, 18 (1st Cir.2000) (discussing and applying these provisions).
Sandra COOMBS, Petitioner, Appellant,
v.
STATE OF MAINE, Respondent, Appellee
99-1245.
Court of Appeals for the First Circuit.
Feb 16, 2000.
202 F.3d 14
Gail E. Peabody, for petitioner. ■, Nancy Torresen, Assistant Attorney General, with whom Andrew Ketterer, Attorney General, and Donald Macomber, Assistant Attorney General, were on brief for respondent.
Selya, Campbell, Boudin.
Cited by 45 opinions  |  Published
LEVIN H. CAMPBELL, Senior Circuit Judge.

Petitioner-appellant Sandra Coombs appeals from the district court’s denial of her petition for habeas corpus relief from her theft conviction in 1996. Coombs contends that she is entitled to relief because the state compelled her confession to the theft by promising not to charge her for possession of a small amount of marijuana discovered at the time of her arrest. We affirm.

I. FACTUAL BACKGROUND

Coombs was charged with the theft of -a sweater from L.L. Bean in Freeport, Maine. On December 16, 1995, her companion, Gifford Campbell, attempted to return a stolen sweater to the L.L. Bean store while Coombs and another individual waited in her car in the parking lot. After detaining Campbell inside the store, a store detective and Freeport Police Sergeant Terry Carter approached Coombs in her car and requested her driver’s license and registration. When Coombs retrieved these items from the car’s glove compartment, Carter saw a small bag of marijuana in the compartment and seized it.

At the suppression hearing, Carter testified that the marijuana was a “very small quantity,” while Coombs testified that it was approximately a quarter of an ounce. At trial, Coombs testified that it was “quite a large amount,” “probably say half a sandwich bag full,” an amount she later described as “serious.” Under Maine law, possession of a usable amount of marijuana would be a- civil, not a criminal, infraction. See 22 M.R.S.A. § 2383(1) (1999). Possession of more than one and one-quarter ounces of marijuana gives rise to a presumption that a person is engaging in unlawful furnishing of marijuana, which is a crime. See 17-A M.R.S.A. § 1106(3)(a) (1999).

Coombs agreed to go into the store with Carter to discuss the matter of the sweater. Carter radioed the Freeport Police Department to request a records check on Coombs. Upon discovering that there was an outstanding warrant for Coombs relating to an unpaid fine, Carter placed her under arrest. He then transported her to the police station and gave her Miranda warnings. Coombs indicated that she understood the warnings, and agreed to answer questions. At no point during the interrogation did Coombs request a lawyer or state that she no longer wanted to answer Carter’s questions.

Carter testified that he interrogated Coombs for “a couple of hours,” but Coombs claimed the questioning went on for “three or four hours.” Coombs testified at the suppression hearing that she was handcuffed to a pole during the entire[*16] interrogation, while Carter testified she was only handcuffed for fifteen to thirty minutes while he photographed and fingerprinted her, and for additional short periods of time while he was out of the room. Coombs further stated that she was afraid and physically uncomfortable during the interrogation, and cried periodically.

Coombs testified that Carter told her that she “could take two charges of theft and possession of marijuana or [she] could confess to the theft and he’d flush the marijuana.” Eventually, Carter asked Coombs to make a “voluntary written statement,” and she agreed. At the suppression hearing, Coombs stated:

I set there handcuffed to a pole for three or four hours, you know, and it’s either you take the — you know, confess to theft or you take both, and I just figured that would be the easiest way to — you know, instead of being handcuffed to the pole for five more hours. I didn’t feel there was any other way.

Contrary to Coombs’s testimony, Carter denied making any promises to Coombs in exchange for her confession, and denied telling her that he would not charge her with marijuana possession if she confessed to the theft. He testified, however, that he had originally intended to charge her with possession of marijuana and had written a summons for that offense. Moreover, he conceded that after Coombs signed the written confession, he flushed the marijuana down the toilet and tore up the summons. [1] Carter offered no explanation for these actions at the suppression hearing; at trial, he testified that he “felt bad” for Coombs.

II. PROCEDURAL HISTORY

On January 11, 1996, Coombs was charged in the state district court with Class E theft pursuant to 17-A M.R.S.A. § 353 (1983). See State v. Coombs, No. 95-03959 (Maine Dist. Ct., Div. Bath-Brunswiek). Class E theft is punishable by no more than six months’ imprisonment. See 17-A M.R.S.A. § 1252(2)(E). Coombs pleaded not guilty at her arraignment. On February 26, 1996, she filed a motion to suppress her written confession on the ground that the confession had been compelled by the state’s promise to drop the marijuana charge, and was therefore involuntary under the Fifth Amendment to the United States Constitution.

After an evidentiary hearing on the suppression motion, the Maine district court (“the suppression court”) denied the motion. The suppression court found, inter alia, that Coombs was read her Miranda warnings at the station house; indicated that she understood the warnings; did not request counsel; did not tell Carter that she wanted to stop answering questions; was handcuffed to a horizontal rail during some intermittent periods of time during the interrogation when she was left alone by Carter, who was going between Coombs’s room and another suspect’s room; and was interrogated for approximately two to three hours. As to Carter’s alleged promise of leniency in exchange for Coombs’s confession, the court stated:

I’m satisfied that there were no promises which would give rise to a constitutional infirmity, and I’m satisfied beyond a reasonable doubt that the con — that the admission or the statement or whatever is in this was, in fact, voluntary.

Coombs’s confession was admitted into evidence at her trial, which took place in the Maine Superior Court. On September 10, 1996, following a two-day trial, the jury returned a guilty verdict. The court sentenced Coombs to thirty days’ imprisonment, but stayed the sentence pending appeal and the instant proceedings.

On September 27, 1996, Coombs appealed from her conviction to the Maine Supreme Judicial Court sitting as the Law[*17] Court pursuant to 15 M.R.S.A. § 2115 and M.R.Crim. P. -37. Her appeal focused on the voluntariness of her confession, and.the voluntariness of her waiver of Miranda rights. The Law Court affirmed Coombs’s conviction on January 2, 1998. State v. Coombs, 704 A.2d 387 (Me.1998). Accepting the suppression court’s findings that Coombs was handcuffed only intermittently (which the Law Court construed, based on Carter’s testimony, to have been fifteen to thirty minutes) and that proper Miranda procedures were followed, the Law Court rejected Coombs’s argument that her theft confession should have been suppressed. See id. at 391. On the question of whether the confession was involuntary because it was given in exchange for Carter’s promise not to charge her with marijuana possession, the court stated:

A confession motivated by a promise of leniency by a person with apparent authority' to execute the promise is involuntary and inadmissible. State v. Tardiff, 374 A.2d 598, 601 (Me.1977). At the suppression hearing, Sergeant Carter testified that he ' did not promise Coombs anything in exchange for her confession and, although he conceded that he flushed the marijuana down the toilet, he denied telling Coombs that she would not be charged with possession if she confessed to the theft. Although Coombs testified to the contrary, the suppression judge, as the fact finder, was free to accept Sergeant Carter’s testimony over Coombs’. See State v. Larrivee, 479 A.2d 347, 349 (Me.1984); State v. Knights, 482 A.2d 436, 442 (Me.1984). The trial court’s finding is based on competent evidence and is not clearly erroneous.

Id. The Law Court also rejected Coombs’s contention that that finding was ambiguous:

The suppression judge found that “there were no promises which would give rise to a constitutional infirmity[.]” Coombs contends that this finding is ambiguous, that it is unclear whether the suppression judge found that no promise had been made or that a promise of no constitutional significance had been made. Because we assume that the suppression judge found for the prosecution on all issues of fact necessarily raised by his denial of the motion to suppress, State v. Cefalo, 396 A.2d 233, 239 n. 12 (Me.1979), we reject Coombs’ contention.

Id. at 391 n. 4.

On April 1, 1998, Coombs filed a petition for a writ of certiorari in the United States Supreme Court, again on Fifth Amendment grounds. The Court denied her petition on May 18, 1998. Coombs v. Maine, 523 U.S. 1129, 118 S.Ct. 1819, 140 L.Ed.2d 956 (1998). Next, on October 5, 1998, she filed a petition for a writ of habeas corpus in the federal District Court for the District of Maine, limiting her argument to the voluntariness of her confession. The magistrate judge held that the Anti-Terrorism and Effective Death Penalty Act of 1996, Pub.L. No. 104-132, 110 Stat. 1214 (“AEDPA”), on which the state relied, did not apply to Coombs’s habeas petition. Rather, he applied a pre-AEDPA standard, which permitted state court findings of fact to be overturned only if “not fairly supported by the record.” The magistrate judge concluded that the voluntariness of Coombs’s confession was supported by Carter’s testimony. He went on to hold that his conclusion would be the same even under an independent review of the totality of the circumstances.

On January 11, 1999, the district court affirmed the’ magistrate judge’s recommended decision and dismissed Coombs’s petition, but for reasons other than those set forth by the magistrate judge. See Coombs v. Maine, Civ. No. 98-346-P-C (D.Me. Jan. 11, 1998). The district court held that AEDPA applied to Coombs’s petition, so that the state court’s factual findings were “presumed to be correct” pursuant to 28 U.S.C. § 2254(e)(1). It further noted that AEDPA permitted it to grant the petition only if the trial court’s determination “was contrary to ... clearly es[*18] tablished federal law as decided by the Supreme Court” or “resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.” See 28 U.S.C. § 2254(d)(1) & (2). The district court concluded that the suppression court’s decision was neither contrary to clearly established federal law nor based on an unreasonable determination of the facts. Coombs timely filed a notice of appeal to this court on-January 22,1999.

III. DISCUSSION

In reviewing a ruling on a petition for a writ of habeas corpus, we examine the district court’s legal conclusions de novo. See Simpson v. Matesanz, 175 F.3d 200, 205 (1st Cir.1999). As the district court correctly held (and the parties do not contest), the standard of review to be applied is set forth by Congress in the AED-PA statute. AEDPA provides that in a habeas proceeding, “a determination of a factual issue made by a State court shall be presumed to be correct,” and the petitioner has the burden of rebutting the presumption of correctness by clear and convincing evidence. 28 U.S.C. § 2254(e)(1). For this purpose, “factual issues” are defined as “basic, primary, or historical facts: facts ‘in the sense of a recital of external events and the credibility of their narrators.’ ” Bryson v. Ward, 187 F.3d 1193, 1211 (10th Cir.1999), quoting Townsend v. Sain, 372 U.S. 293, 83 S.Ct. 745, 9 L.Ed.2d 770 (1963). See also Thompson v. Keohane, 516 U.S. 99, 112-13, 116 S.Ct. 457, 133 L.Ed.2d 383 (1995) (interpreting pre-AEDPA version of habeas statute). [2]

A state court’s ultimate conclusions, including its legal rulings, are reviewed pursuant to another clause of AEDPA, allowing habeas relief only where the state court’s adjudication

(1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal- law, as determined by the Supreme Court of the United States; or
(2) resulted in a decision that 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). This provision governs not only pure issues of law, but mixed questions of law and fact in which legal principles are applied to historical facts. See Trice v. Ward, 196 F.3d 1151, 1169 (10th Cir.1999); Sanchez v. Gilmore, 189 F.3d 619, 623 (7th Cir.1999). See also O’Brien v. Dubois, 145 F.3d 16, 22-23 (1st Cir.1998).

If the suppression court upheld the confession because it credited Carter’s testimony that he had made no promise to flush the marijuana in return for Coombs’s confession to theft, Coombs’s case for federal habeas relief largely evaporates. Such a state court finding of “basic, primary, or historical facts” based on a credibility determination is “presumed to be correct,” subject only to rebuttal by “clear and convincing evidence.” 28 U.S.C. § 2254(e)(1). We find no rebuttal of that nature here.

Coombs’s argument on appeal from the denial of her habeas petition is that the state suppression court’s own finding that “there were no promises which would give rise to a constitutional infirmity” fell short of indicating that it credited Carter’s version of events rather than Coombs’s. In the absence of an express finding, Coombs urges, the suppression court possibly may have accepted Coombs’s version — that Carter promised to get rid of the marijuana in exchange for a confession of theft— yet still concluded, as a matter of law, that Coombs’s confession was voluntary. In that case, Coombs contends, she has raised[*19] a federal constitutional issue meriting ha-beas review.

To accept Coombs’s position, however, we would have to reject the Maine Law Court’s interpretation of precisely what action was taken by the suppression court, a court under it's jurisdiction. The Law Court clearly believed that the suppression court had credited Carter’s testimony that he did not promise Coombs anything in exchange for her confession. In its opinion, after setting forth the state’s rule that a confession motivated by a promise of leniency “is involuntary and inadmissible,” the court went on to recite Carter’s denial of having made any such promise. Coombs, 704 A.2d at 391. It then stated that while Coombs testified 'to the contrary, the suppression court, as fact finder, “was free to accept Sergeant Carter’s testimony over Coombs’s” and that “the trial court’s finding is based on competent evidence and is not clearly erroneous.” Id. The Law Court thus plainly construed the suppression court as having based its finding of voluntariness on acceptance of Carter’s version of the facts. Indeed, to have accepted Coombs’s version would seemingly be inconsistent with the legal premise stated at the outset of its discussion; instead, it reasonably assumed that the suppression court shared its understanding of the governing law, as previously articulated by the Law Court. Moreover, in footnote 4, the court specifically rejected Coombs’s contention that the suppression court’s finding was ambiguous, opining that the suppression court “found for the prosecution on all issues of fact necessarily raised by his denial of the motion to. suppress.” Id. at 391 n. 4. Even the Law Court justice writing in dissent agreed that the majority assumed a finding that no promise was made. See id. at 393.

Hence, were we to speculate that the suppression court credited Coombs, we would be rejecting an authoritative interpretation by Maine’s highest court of the findings of a subordinate court — and would be doing so on an issue that, although close, was resolved well within reasonable parameters. Under the circumstances, we can see no justification, even were we so inclined, for substituting our own different theory as to what the suppression court might have intended. Cf. Miller v. Fenton, 474 U.S. 104, 112, 106 S.Ct. 445, 88 L.Ed.2d 405 (1985) (federal habeas court must “give great weight to the considered conclusions of coequal' state judiciary”). Additionally, we cannot conclude, given the fact of Carter’s testimony, that the suppression court’s decision, as so construed by the Law Court, was based on an unreasonable determination of the facts in light of the evidence presented in the state proceedings. We hold, therefore, that habeas review is barred under 28 U.S.C. §§ 2254(d)(2) and (e)(1).

To keep the record clear, it is less apparent to us than to the Maine Law Court that if a promise had been made it automatically would have rendered the confession involuntary. See, e.g., United States v. Byram, 145 F.3d 405, 407 (1st Cir.1998) (noting that Supreme Court has “confined” early common-law rule that “confessions produced by promises not to prosecute or offers of leniency were often excluded as involuntary.”); Cole v. Lane, 830 F.2d 104, 109 (7th Cir.1987) (holding that promise of leniency is necessary, but not sufficient, condition of finding of involuntariness); United States v. Parker, 549 F.2d 1217, 1220 (9th Cir.1977) (confession not involuntary where defendant questioned by federal agents for four hours despite disputed testimony concerning use of promises and physical force by agents).

Affirmed.

1

. Maine law prohibits the destruction of physical evidence that might aid in the discovery, apprehension, or conviction of a person accused of a crime. See 17-A M.R.S.A. § 753(l)(c)(1983).

2

. For purposes of Coombs's petition, AEDPA did not meaningfully alter the standard for reviewing determinations of fact. See 28 U.S.C. § 2254(d) (repealed 1996); Bryson, 187 F.3d at 1211.