habeas corpus

Former Detroit police officer Burt Lancaster shot and killed his girlfriend, Toni King, in 1993. As a result, the State of Michigan charged Burt Lancaster with first-degree murder and possession of a firearm while committing a felony. Although Lancaster, who has a history of mental illness, asserted both defenses of insanity and diminished capacity during his initial trial in 1994, a Michigan jury convicted Lancaster on both counts. Lancaster's conviction was subsequently overturned, however, because of an error made by the State during jury selection. The State of Michigan retried Lancaster in 2005. Although Lancaster planned to rely completely on his diminished capacity defense during his second trial, the Michigan trial court prohibited Lancaster from doing so on the grounds that the Michigan Supreme Court abolished the defense in 2001. As Lancaster was unable to assert the diminished capacity defense at his second trial, the Michigan state court convicted Lancaster once again and sentenced him to life plus two years in prison. Lancaster petitioned the federal courts for a writ of habeas corpus. While the District Court denied Lancaster's petition, the Sixth Circuit reversed, finding that the retroactive application of the Michigan Supreme Court's abolishment of the diminished capacity defense violated federal due process. On appeal, the State of Michigan argues that the Michigan state court's decision to prohibit the diminished capacity defense was not an "unexpected and indefensible" abrogation of Michigan law because the diminished capacity defense has never been expressly provided by Michigan statute nor has it been a part of settled Michigan common law. Lancaster responds that he has the constitutional right to present the diminished capacity defense because the defense was well-settled under Michigan law and available to him at the time he committed the murder. The State of Indiana and others argue in support of Michigan, asserting that diminished capacity is a state law issue and federal courts should defer to a state court's analysis. Lancaster responds that the Michigan state court's decision was unreasonable and that a federal court should independently review the Michigan state court's determination. This decision will further outline the prohibition on changes in state judge-made law by determining when the retroactivity prohibition can be used to justify granting habeas corpus relief and by further defining what constitutes an "unexpected and indefensible" change to the common law.

Carlos Trevino was convicted of capital murder and sentenced to death by a Texas jury in 1997. During sentencing, Trevino’s state-appointed trial counsel failed to introduce potentially mitigating evidence of Trevino’s history of extreme childhood abuse and neglect, which might have persuaded the jury to sentence him to life in prison instead of death. His state-appointed habeas corpus counsel also failed to uncover evidence of Trevino’s background, and therefore failed to realize that he might have a colorable ineffective assistance of counsel claim. This failure to assert the claim barred raising the claim on federal habeas corpus review. However, the U.S. Supreme Court in Martinez v. Ryan, No. 10-1001, slip op. at 15 (March 20, 2012), had recognized a narrow exception to the procedural default rule, whereby ineffective assistance of counsel in an initial-review collateral proceeding—here, the state habeas proceeding—may excuse such a default. In Martinez, Arizona made state habeas proceedings the exclusive forum for addressing ineffective assistance of counsel claims.Trevino argues that the Martinez exception should apply here because this case implicates the same equitable considerations in post-conviction systems similar to Arizona’s.  In response, Rick Thaler, Director of the Correctional Institutions Division at the Texas Department of Criminal Justice, contends that Texas’s post-conviction system already provides fair opportunity for such claims to be heard, both in state habeas proceedings and on direct appeal, and thus the Martinez fairness concerns do not apply.  This decision may affect the legitimacy of the state post-conviction process and the balance of victims’ rights and the rights of capital inmates in the post-conviction setting.

A Michigan court convicted Lloyd Perkins of murder and sentenced him to life in prison. Nearly twenty years later, Perkins is now challenging his conviction based on new evidence supporting his innocence. The lower courts rejected Perkins’ petition for a writ of habeas corpus because of his failure to meet the statute of limitations according to the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”). Perkins maintains that Supreme Court precedent does not require petitioners to reasonably and diligently pursue their underlying constitutional claims to invoke an actual-innocence exception. Perkins also argues that, since traditional equitable principles dictate that courts have the authority to fashion equitable remedies to fill statutory gaps, tolling AEDPA’s one-year statute of limitations does not run contrary to express congressional intent. McQuiggin counters that AEDPA’s one-year statute of limitations cannot be equitably tolled for petitioners who have failed to reasonably and diligently pursue their constitutional claims. Furthermore, McQuiggin argues that courts cannot equitably toll AEDPA’s one-year statute of limitations in Perkins’ case because doing so would alter the express meaning of 28 U.S.C. § 2244(d)(1). This case will determine the responsibilities of federal courts in hearing habeas corpus petitions and define the avenues in which inmates can attempt to prove their innocence. 

Sean Carter was convicted of aggravated murder, aggravated robbery, and rape, and was sentenced to death in Ohio. His counsel filed a federal habeas corpus petition challenging his conviction and requested a pre-petition competency hearing to determine whether Carter was competent to participate in the federal habeas proceeding. The district court granted both the petition and the request. Two years later, the district court determined that Carter was incompetent and dismissed his petition while also stopping the one-year statute of limitations. When the warden at the facility where Carter is imprisoned challenged the district court's decision, the United States Court of Appeals for the Sixth Circuit determined that even though the district court was justified in finding Carter incompetent, the proper course of action was to stay, rather than dismiss, the habeas proceedings until Carter was competent. Another warden now argues that a district court does not have the authority to stay federal habeas proceedings, nor does Carter have a right to competence in his own habeas proceedings. How the Supreme Court decides this case will determine the balance between recognizing the finality of state-court criminal judgments and allowing federal courts to use their discretion to implement stays in federal habeas proceedings where a capital prisoner’s competence to assist counsel is questionable.