JOHN M. WALKER, JR., Chief Judge.
Petitioner Jesse Hines appeals from the July 11, 2001 denial of a petition for a writ of habeas corpus by the United States District Court for the Southern District of New York (Lewis A. Kaplan, District Judge). In his petition, Hines’s claimed that (1) he was denied due process by the state trial court’s failure to appoint new counsel and hold a new hearing on his motion to withdraw his guilty plea; (2) he received ineffective assistance of counsel because his counsel coerced him to plead guilty; and (3) he received ineffective assistance of counsel by his counsel’s failure to represent him on the motion to withdraw his plea. The district court rejected Hines’s claims, but issued a certificate of appealability “limited to the questions [of] whether petitioner was (1) entitled, as a matter of constitutional law, to an eviden-tiary hearing, and (2) deprived of the effective assistance of counsel when he moved to withdraw his plea.” Hines v. Miller, 156 F.Supp.2d 324, 333 (S.D.N.Y.2001) (“Hines II ”). Hines renews his claims on appeal. While we affirm the district court’s denial of the petition, we do so on different grounds.
BACKGROUND
In early 1995, Hines was indicted for second degree murder and related weapons charges in connection with the shooting death of Earl Murray on January 23, 1994. During his interrogation with police detectives, Hines made oral, written, and videotaped statements in which he admitted killing Murray. Specifically, in a five-page hand-written statement, Hines admitted that a man named Mark offered him $1500 to shoot Murray and gave him a .38-caliber revolver. Hines explained that the offer “seem[ed] so good” to him because his mother had just passed away, his aunt had kicked him out of her house, and he could use the money to find an apartment. Moreover, Mark told him that he “would never get court [sic]” and “that as long as [159]*159I was with him I wouldn’t get hurt.” Hines, Mark, and Murray then went for a walk together, and when they were
behind the back of 1695 [Madison Avenue] ... Mark said, “Go ahead remember the 1,500” and then I shot him. I shot him one time and Mark said, “Shoot again” but I couldn’t do it. So I was standing there Earl began to fall and when he hit the floor Mark take his [cigarette] and [throw] it on Earl and then laugh. After that I run and drop the gun but I don’t stop.
If convicted as charged, Hines faced a possible sentence of twenty-five to life. Hines’s attorney engaged in extensive plea negotiations with the district attorney, who agreed to the minimum sentence of fifteen years to life if Hines pleaded guilty to the first count of the indictment charging murder in the second degree. To assist Hines in deciding whether to accept the plea offer, Hines’s attorney arranged to show Hines his videotaped confession. The next day, June 13, 1996, Hines discussed the possibility of a plea with his aunt in the presence of the state court judge; his aunt apparently thought that “it would be good for” Hines to accept the plea offer. Immediately following this conversation with his aunt, Hines pleaded guilty to murder in the second degree. During the course of the plea proceedings, and prior to accepting the plea, the state trial court fully explained petitioner’s rights to him. Hines specifically acknowledged that no one had forced him to plead guilty. The trial court then proceeded to question him about the crime, in response to which Hines admitted that he shot the victim with a gun on the date in question. The case was then set for sentencing.
Less than one week before sentencing, Hines filed a pro se motion to withdraw his plea on the ground that he was innocent and had been coerced into pleading guilty by his attorney. When the case came on for sentencing before the state trial court, defense counsel declined to comment on Hines’s allegation that counsel had pressured him into pleading guilty, but asked to be relieved in the event the court allowed withdrawal of the plea. The prosecutor made a statement opposing the motion. In response to the prosecutor’s statement, defense counsel noted that he was “at a great disadvantage to defend the defendant” and asked the court to be relieved and to have new counsel appointed to argue the motion on proper papers. The trial court did not relieve counsel. Rather than address the request, the trial court questioned Hines directly, pointing out that he had stated on the occasion of his guilty plea that no one had forced him to plead guilty. Hines responded that his counsel “wanted me to cop out” from the outset of the case, and that on the day his attorney showed him the videotape of his confession, his attorney told him “that I have no chance to win at trial, to cop out would be better for me.” Hines went on to state that he was innocent of the crime and had only pleaded guilty “out of fear, pressure, extreme pressure.” The state trial court then asked Hines whether he had spoken to his aunt before pleading guilty, and he responded, ‘Tes, I did. She thought it would be good for me to take the 15 too. So I took it but — .” Noting that Hines had inculpated himself fully when he entered the guilty plea and that he had stated then that no one had forced him to plead guilty, the state trial court denied the motion and proceeded immediately to sentencing, imposing the agreed-upon term of fifteen years to life imprisonment.
Hines appealed to the Appellate Division, arguing that the denial of the motion to withdraw the plea without appointing new counsel and without conducting an [160]*160evidentiary hearing violated his right to due process of law under both the United States and New York Constitutions as well as the New York Criminal Procedure Law. Petitioner submitted a supplemental pro se brief in which he argued that he had received ineffective assistance of counsel, in violation of both federal and state constitutions, because, among other things, his attorney used a videotape of his confession to induce him to plead guilty.
The Appellate Division affirmed the conviction. People v. Hines, 267 A.D.2d 17, 698 N.Y.S.2d 491 (1999) (“Hines I”). Petitioner then applied for leave to appeal to the New York Court of Appeals, which was denied by order dated March 19, 2000. People v. Hines, 94 N.Y.2d 921, 708 N.Y.S.2d 360, 729 N.E.2d 1159 (2000).
Hines timely filed this petition for a writ of habeas corpus, pursuant to 28 U.S.C. § 2254, arguing that he was deprived of his right to due process of law when the trial court denied his motion to withdraw his guilty plea without appointing new counsel or holding an evidentiary hearing and that he was deprived of the effective assistance of counsel.
DISCUSSION
I. Standard of Review
We review the district court’s denial of habeas corpus de novo. Sellan v. Kuhlman, 261 F.3d 303, 308 (2d Cir.2001).
Under the Antiterrorism and Effective Death Penalty Act of 1996 (“AED-PA”), Pub.L. No. 104-132, 110 Stat. 1214, 1217 (codified at, inter alia, 28 U.S.C. § 2254), a petition for a writ of habeas corpus may not be granted with respect to a state court decision that has “adjudicated [a petitioner’s claims] on the merits” unless the state court’s decision “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.” 28 U.S.C. § 2254(d)(1). State court decisions that have not “adjudicated [claims] on the merits” are subject to the pre-AEDPA de novo standard of review. See Washington v. Schriver, 255 F.3d 45, 55 (2d Cir.2001). In Washington, issued shortly before the district court’s decision in this case, we discussed the uncertainty of the meaning of the phrase “adjudicated on the merits” as used in § 2254. Id. at 52-55.
The district court, citing Washington and noting the brevity of the Appellate Division’s memorandum decision, declined to decide whether the Appellate Division had adjudicated Hines’s federal constitutional claims on the merits, concluding that the petition failed whether AEDPA’s deferential standard or pre-AEDPA de novo review applied. Hines II, 156 F.Supp.2d at 328-29.
In Sellan, decided after the district court filed its opinion, we held that “adjudication on the merits” requires only that a claim be disposed of on the merits, as opposed to on a procedural or other ground, and that the state court need not refer to the federal claim or to federal law as a prerequisite to the deferential AED-PA standard under 28 U.S.C. § 2254(d)(1). Sellan, 261 F.3d at 312. In affirming Hines’s conviction, the Appellate Division held that
[a]fter a thorough inquiry, the court properly denied defendant’s motion to withdraw his guilty plea. The record establishes that defendant made a voluntary plea and fails to substantiate his claims of coercion and innocence. The conduct by his attorney that defendant claimed to have been coercive amounted to nothing more than the attorney’s professional opinion on the strength of the case and sound advice to plead guilty. [161]*161Defendant’s claim of innocence was con-clusory and was belied by Ms oral, written and videotaped confessions. Defense counsel properly declined to join in defendant’s pro se motion to withdraw his plea since the motion lacked merit, and appointment of new counsel was not required (People v. Simpson, 238 A.D.2d 193, 656 N.Y.S.2d 724), We conclude that defendant received meaningful representation (see People v. Ford, 86 N.Y.2d 397, 404, 633 N.Y.S.2d 270, 657 N.E.2d 265). We have considered and rejected defendant’s remaining claims.
Hines I, 698 N.Y.S.2d at 491-92.
In light of Sellan, we conclude that Hines’s claims were adjudicated on the merits. Accordingly, we hold that the state court’s decision in this case should be reviewed under the AEDPA standard of deference. See 28 U.S.C. § 2254(d).
The Supreme Court has stated that under AEDPA’s “unreasonable application” clause, habeas relief is warranted only “if the state court identifies the correct governing legal principle from [the Supreme Court’s] decisions but unreasonably applies that principle to the facts of the prisoner’s case.” Williams v. Taylor, 529 U.S. 362, 413, 120 S.Ct. 1495, 146 L.Ed.2d 389 (2000). Thus, a “federal habeas court may not issue the writ simply because that court concludes in its independent judgment that the relevant state-court decision applied clearly established federal law erroneously or incorrectly.” Id. at 411. Rather, the state-court’s application must also be “objectively unreasonable.” Id. at 409, 120 S.Ct. 1495. As will be further explained, Hines’s claims fail to meet this standard.
II. Failure to Hold a Hearing
Hines argues that he was denied due process by the state court’s refusal to hold an evidentiary hearing on his motion to withdraw his guilty plea. Although the basis for the motion to withdraw was that he was coerced by counsel to plead guilty, he argues that a hearing was required because there was significant evidence in the record of Ms actual innocence, referring to statements taken from several witnesses that indicated that Hines’s co-defendant, rather than Hines, had committed the murder.
In rejecting the claim that Hines should have been given an evidentiary hearing on the withdrawal motion, the district court analogized to federal practice on plea withdrawal motions, noting that under Fed. R.Crim.P. 32(e), an evidentiary hearing is not mandatory. Hines II, 156 F.Supp.2d at 329-30. The district court then analyzed the due process claim under the balancing test developed for administrative proceedings in Mathews v. Eldridge, 424 U.S. 319, 96 S.Ct. 893, 47 L.Ed.2d 18 (1976). Hines II, 156 F.Supp.2d at 330-31. The district court concluded that while Hines’s liberty interest and his interest in having a jury determine his guilt cut in favor of requiring a hearing, the failure to hold a hearing posed little risk of an erroneous decision because Hines raised no basis for vacating his plea that did not contradict his own prior statements made in open court, and the burden on the government of requiring evidentiary hearings on plea withdrawal motions like this one would be substantial and would significantly outweigh any conceivable benefit. Id.
Although not disputing the outcome in the district court, the state argues that the district court erroneously relied on Mathews. We agree. The Supreme Court has stated that it is inappropriate to employ the Mathews balancing test in criminal cases. Medina v. California, 505 U.S. 437, 442-46, 112 S.Ct. 2572, 120 L.Ed.2d 353 (1992). Instead, “[t]he proper analytical approach” to deciding whether state crimi[162]*162nal procedural rules violate due process is to determine if they “ ‘offend[ ] some principle of justice so rooted in the traditions and conscience of our people as to be ranked as fundamental.’ ” Id. at 445, 112 S.Ct. 2572 (quoting Patterson v. New York, 432 U.S. 197, 202, 97 S.Ct. 2319, 53 L.Ed.2d 281 (1977)).
Both federal and state precedent have established that a defendant is not entitled as a matter of right to an eviden-tiary hearing on a motion to withdraw a guilty plea. See, e.g., United States v. Avellino, 136 F.3d 249, 260-61 (2d Cir.1998); United States v. Maher, 108 F.3d 1513, 1529-30 (2d Cir.1997); United States v. Williams, 23 F.3d 629, 635 (2d Cir.1994); United States v. Gonzalez, 970 F.2d 1095, 1100 (2d Cir.1992); People v. Fiumefreddo, 82 N.Y.2d 536, 605 N.Y.S.2d 671, 649-50, 626 N.E.2d 646, 674-75 (1993); People v. Frederick, 45 N.Y.2d 520, 410 N.Y.S.2d 555, 382 N.E.2d 1332, 1334 (1978). In light of these precedents, the failure to hold an evidentiary hearing on a motion to withdraw a plea does not offend a deeply rooted or “fundamental” principle of justice. Thus, under AEDPA’s deferential standard and the Supreme Court’s decision in Medina, the Appellate Division’s conclusion that the state court had conducted a “thorough inquiry, ... [and] properly denied defendant’s motion to withdraw his guilty plea [where] [t]he record establishes that defendant made a voluntary plea and fails to substantiate his claims of coercion and innocence,” Hines I, 698 N.Y.S.2d at 491, was not an unreasonable application of clearly established Federal law. Accordingly, we affirm the district court’s rejection of this claim.
III. Ineffective Assistance of Counsel Based on Coercion of Plea
On appeal, Hines appears to renew his claim from state court that he was denied effective assistance of counsel when his attorney coerced him to plead guilty. The district court, however, granted a certificate of appealability “limited to the questions of whether petitioner was (1) entitled, as a matter of constitutional law, to an evidentiary hearing, and (2) deprived of the effective assistance of counsel when he moved to withdraw his plea.” Hines II, 156 F.Supp.2d at 333. Because the coercion claim was not included in the certificate of appealability, we do not have jurisdiction to review it here. See Smaldone v. Senkowski 273 F.3d 133, 139 (2d Cir.2001) (holding that appellate jurisdiction is limited to the issues contained in the certificate of appealability).
IV. Ineffective Assistance Based on Motion to Withdraw the Plea
With respect to his motion to withdraw his guilty plea, Hines argues that he received ineffective assistance of counsel based on his attorney’s failure to represent him on the motion. The district court construed Hines’s petition to argue that his motion to withdraw his plea based on his attorney’s coercion created an actual conflict of interest that left him effectively unrepresented. Hines II, 156 F.Supp.2d at 331.
The district court, as discussed above, reviewed Hines’s claim de novo, and rejected it on the grounds that (1) Hines’s allegations of coercion did not create a conflict because counsel had not been ineffective in urging Hines to plead guilty, in light of his confessions and the favorable terms of the plea agreement; and (2) even if there had been an actual conflict, Hines could not show that his attorney’s performance had been adversely affected because challenging the voluntariness of his plea was not a “plausible alternative defense strategy” that should have been pursued in light of his confessions and his [163]*163statements at the plea allocution. Hines II, 156 F.Supp.2d at 381-33.
Because, as we have stated, the state court’s decision should have been analyzed under AEDPA’s deferential standard, we need not decide whether the district court’s analysis was correct. Instead, we focus on the reasonableness of the Appellate Division’s decision, which held that (1) Hines’s claims of coercion and innocence were not supported by the record; (2) his attorney did not coerce him, but simply gave him sound advice as to the strength of his case; (3) his attorney properly declined to join in the withdrawal motion; (4) appointment of new counsel was not required; and (5) Hines received meaningful representation. Hines I, 698 N.Y.S.2d at 491-92.
The Supreme Court has, of course, issued numerous opinions concerning various aspects of a defendant’s right to counsel. See e.g., Strickland v. Washington, 466 U.S. 668, 684-96, 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984); Cuyler v. Sullivan, 446 U.S. 335, 348-49, 100 S.Ct. 1708, 64 L.Ed.2d 333 (1980); Coleman v. Alabama, 399 U.S. 1, 7-11, 90 S.Ct. 1999, 26 L.Ed.2d 387 (1970); Mempa v. Rhay, 389 U.S. 128, 134-37, 88 S.Ct. 254, 19 L.Ed.2d 336 (1967); Gideon v. Wainwright, 372 U.S. 335, 339-45, 83 S.Ct. 792, 9 L.Ed.2d 799 (1963). But the Court has never specifically addressed a claim such as the one before us, nor has it stated how such a claim should be analyzed, i.e., as a claim that petitioner was denied his right to counsel because he was effectively unrepresented on his motion to withdraw his plea, see, e.g., Coleman, 399 U.S. at 7-11, 90 S.Ct. 1999; Mempa, 389 U.S. at 134-37, 88 S.Ct. 254, or as a claim that petitioner was denied the effective assistance of counsel because an actual conflict of interest adversely affected counsel’s performance, see, e.g., Cuyler, 446 U.S. at 348, 100 S.Ct. 1708.
Several lower federal courts that have addressed facts similar to ours have viewed the issue at hand in the same way as the dissent does here: whether the failure to appoint substitute counsel on the motion to withdraw was a violation of the right to counsel. See, e.g., United States v. Gonzalez, 113 F.3d 1026, 1029 (9th Cir.1997); United States v. Sanchez-Barreto, 93 F.3d 17, 20-23 (1st Cir.1996); United States v. Garrett, 90 F.3d 210, 212-13 (7th Cir.1996); United States v. Attar, 38 F.3d 727, 732-35 (4th Cir.1994); United States v. Crowley, 529 F.2d 1066, 1069-71 (3d Cir.1976); United States v. Joslin, 434 F.2d 526, 529-30 (D.C.Cir.1970).
Other courts, including ours, however, have applied Strickland v. Washington, Cuyler v. Sullivan, or a similar analysis to determine whether the defendant received ineffective assistance of counsel, and have generally decided the case on the basis of whether the underlying motion had sufficient merit to create an actual conflict of interest or present a “plausible alternative defense strategy.” See, e.g., United States v. Morris, 259 F.3d 894, 899 (7th Cir.2001); United States v. Davis, 239 F.3d 283, 285-88 (2d Cir.2001); United States v. Moree, 220 F.3d 65, 69-72 (2d Cir.2000); Lopez v. Scully, 58 F.3d 38, 41-43 (2d Cir.1995); United States v. Craig, 985 F.2d 175, 178-80 (4th Cir.1993); United States v. Trussel, 961 F.2d 685, 688-90 (7th Cir.1992); Guzman v. Sabourin, 124 F.Supp.2d 828, 833, 834-36 (S.D.N.Y.2000); Fluitt v. Superintendent, Green Haven Corr. Facility, 480 F.Supp. 81, 85-87 (S.D.N.Y.1979) (Weinfeld, J.).
And some courts have applied more than one analysis. See, e.g., United States v. Caban, 962 F.2d 646, 648-50 (7th Cir.1992) (analyzing as right to counsel, ineffective assistance, and under Rule 32); United States v. Ellison, 798 F.2d 1102, 1106-09 [164]*164(7th Cir.1986) (analyzing under Cuyler and as denial of right to counsel).
Moreover, numerous reviewing courts, irrespective of the analysis employed, have affirmed the denial of a withdrawal motion despite the failure to appoint new counsel. See, e.g., Moree, 220 F.3d at 69-72 (finding no conflict of interest); Lopez, 58 F.3d at 40-42 (finding motion was not a “plausible alternative defense strategy”); Attar, 38 F.3d at 735 (analyzing as denial of right to counsel but finding no abuse of discretion by district court where motion appeared to simply be dilatory tactic); Craig, 985 F.2d at 179-80 (finding no prejudice resulting from counsel’s ineffectiveness); Caban, 962 F.2d at 649-50 (analyzing as denial of right to counsel but finding allegations unreliable under Fed.R.Civ.P. 32); Trussel, 961 F.2d at 688-90 (finding counsel was not shown to be ineffective); Crowley, 529 F.2d at 1069-71 (finding denial of right to counsel was harmless error); Fluitt, 480 F.Supp. at 85-87 (finding that there was no conflict or denial of counsel in light of frivolity of motion).
Given the many divergent approaches and outcomes in federal courts that have applied clearly established Supreme Court precedent to the facts at issue and the absence of any Supreme Court decision concerning this type of claim, we find no basis for concluding — as the dissent does— that the Appellate Division’s decision here constituted an unreasonable application of clearly established Federal law as determined by the Supreme Court of the United States. Accordingly, we affirm the district court’s rejection of this claim.
CONCLUSION
For the reasons set forth above, the judgment of the district court denying Hines’s petition for a writ of habeas corpus is hereby Affirmed.