The plaintiff/respondent in Philip Morris v. Williams (Williams III) has filed her brief on the merits. You can view the brief on the ABA’s website here. Links to the petitioner’s brief on the merits and supporting amicus briefs can be found in this post.

To recap, the issued presented in Williams III is:

Whether, after this Court has adjudicated the merits of a party’s federal claim and remanded the case to state court with instructions to “apply” the correct constitutional standard, the state court may interpose–for the first time in the litigation–a state-law procedural bar that is neither firmly established nor regularly followed.

The case will be argued December 3.