Federal statute and this Court's rulings provide that a district court must grant an evidentiary hearing when material facts are contested, and those facts occurred outside the courtroom and off-the-record. Mr. Thomas's § 2255 claims involves counsel's failure to investigate an exculpatory alibi-like defense. Despite the silent record, the district court chose to resolve the factual dispute without an evidentiary hearing. The Eleventh Circuit Court of Appeals refused to review the district court's non-evidentiary resolution of the § 2255 motion. Would jurists of reasons have debated the correctness of the district court electing to ignore the governing statute on § 2255 hearings?

Whether the district court erred in denying an evidentiary hearing on a § 2255 motion without resolving contested material facts