Quick follow-up on habeas reversal rates

I posted yesterday about CA3’s dropping reversal rate. I noted the overall drop was driven by a dramatic drop in CA3’s reversal rate for prisoner-petition appeals, including habeas, and I hypothesized that two 2011 Scotus habeas opinions might help explain why.

I was floored by what I’d found. Here’s a little more perspective from the other circuits. I’ve limited the years and focused on private-prisoner-petition cases, which includes habeas but does not include 2255s:

So CA3 was not the only circuit that dramatically lowered its reversal rate between 2011 and 2012: so did CA1, CA4, CA5, and CA7. And between 2012 and 2013, the reversal rate dropped in all 11 circuits.

Indeed, adding a couple more years’ data, it’s notable how similar the curves for CA4, CA5, and CA7 are to CA3’s:

2011 peaks, 2012 plunges. This still doesn’t prove that Richter and Pinholster caused the reversal-rate drop, but it does confirm that CA3’s experience is not unique.

* I’ve omitted the DC circuit due to their tiny numbers in this category. They had 12 cases and affirmed in all.