habeas corpus

Oral argument: Oct. 4, 2011

Appealed from: United States Court of Appeals for the Sixth Circuit (Mar. 5, 2010)

While Randall Fields was incarcerated, officers unaffiliated with the prison questioned him regarding activities unrelated to his incarceration. Fields made incriminating statements to the officers, and was convicted after these statements were admitted into evidence. The U.S. Court of Appeals for the Sixth Circuit granted Fields' petition for habeas corpus relief, holding that the state court decision was in conflict with clearly established Supreme Court precedent forbidding the admission of statements made without the protection of Miranda warnings. The Supreme Court granted certiorari to determine whether a prisoner is "in custody," and thus entitled to Miranda protections, any time the prisoner is separated from the general prison population and questioned. Petitioning Warden Carol Howes contends that habeas should not be granted because the state court’s decision is not in conflict with any clearly established precedent of the Supreme Court. In contrast, Respondent Fields argues that there is a clearly established rule granting Miranda protection to prisoners anytime they are isolated and questioned. Howes maintains that recognizing a Supreme Court precedent requiring Miranda rights to be issued any time a prisoner is questioned will grant prisoners greater protections than those given to ordinary citizens. Fields counters that requiring officers to issue Miranda warnings is essential to protecting prisoners’ Fifth Amendment rights.

Oral argument: Nov. 29, 2010

Appealed from: United States Court of Appeals for the First Circuit (Sept. 23, 2009)

CRIMINAL LAW, HABEAS CORPUS, ANTI-TERRORISM AND EFFECTIVE DEATH PENALTY ACT

In December 1993, Khalil Kholi was convicted of sexual assault in the first degree and was sentenced to life imprisonment. Three years later, Kholi filed a motion to reduce his sentence, seeking discretionary leniency in state court. In 2007, Kholi filed a habeas corpus petition in federal court. The federal district court denied Kholi's petition on the grounds that it was not timely filed under the Anti-Terrorism and Effective Death Penalty Act ("AEDPA”). The First Circuit reversed, holding that a discretionary post-conviction motion to reduce a sentence constitutes collateral review under 28 U.S.C. § 2244(d)(2) and tolls AEDPA's one-year limitation period. Petitioner A.T. Wall appealed, arguing that a discretionary sentence-reduction motion does not constitute collateral review because it does not challenge the validity of a conviction or sentence. Kholi counters that collateral review includes motions seeking equitable, discretionary relief, and argues that his motion seeking a discretionary reduction of an imposed sentence tolls AEDPA's statute of limitations. The Supreme Court's decision will affect the finality of state court judgments, as well as the state court remedies a prisoner can pursue before filing a petition for federal habeas corpus relief.

Oral argument: Nov. 29, 2010

Appealed from: United States Court of Appeals for the Ninth Circuit (Oct. 6, 2009)

HABEAS CORPUS, PROCEDURAL BAR, ADEQUATE STATE GROUNDS DOCTRINE, TIMELINESS

Charles Martin is serving life imprisonment for the robbery and first-degree murder of Charles Stapleton. After exhausting his direct appeals, Martin filed a petition for habeas corpus in California state court, alleging that his trial counsel was ineffective. The California Supreme Court eventually dismissed the petition under the state’s “timeliness” rule, which bars claims filed after “substantial delay.” Martin then filed a habeas corpus claim in federal court on similar grounds. The federal district court found that the state timeliness grounds were “adequate” for dismissal of the federal case. Under the adequate state grounds doctrine, a federal court will not review the decision of a state court if the federal court’s decision would have no impact on the case. The Ninth Circuit reversed, finding that the state had failed to prove that California’s timeliness rule was sufficiently clear and consistently applied so as to be an adequate state bar. Martin argues that the Ninth Circuit was correct in its ruling, while Petitioner James Walker counters that the rule is indeed consistently applied. If the Supreme Court finds the rule adequate, this will likely increase denials of federal habeas corpus petitions; if the rule is not adequate, however, California may be required to use a more precise standard in determining what constitutes an untimely petition.

Oral argument: Nov. 9, 2010

Appealed from: United States Court of Appeals for the Ninth Circuit (Dec. 9, 2009)

HABEAS CORPUS, INEFFECTIVE ASSISTANCE OF COUNSEL, EVIDENTIARY HEARING

After receiving a death sentence in state court, Scott Pinholster submitted a habeas corpus petition in California federal district court claiming that his attorney’s deficient performance at trial violated his Sixth Amendment right to fair representation. Though the state court had dismissed Pinholster’s petition on the merits, the federal district court agreed to conduct an evidentiary hearing on new facts regarding Pinholster’s medical and family history that were available but not presented during the sentencing phase of Pinholster’s state trial. The federal district court eventually granted habeas relief, and the Ninth Circuit Court of Appeals affirmed, ordering a new sentencing proceeding. Now, the Warden at San Quentin State Prison argues that the new facts presented during the federal evidentiary hearing violated Section 2254 of the Antiterrorism and Effective Death Penalty Act of 1996 because these facts were not first presented in state court. The Supreme Court’s decision in this case will affect the circumstances under which a federal habeas court may allow for evidentiary hearings that introduce facts not considered by state courts below.

Oral argument: Oct. 13, 2010

Appealed from: United States Court of Appeals for the Fifth Circuit (Feb. 2, 2010)

FEDERAL HABEAS CORPUS, CIVIL RIGHTS, DNA TESTING, CAPITAL MURDER

Florida convicted petitioner Henry Skinner of capital murder and sentenced him to death. Although Skinner admits that he was present at the scene of the murders, he maintains his innocence. Skinner now seeks access to biological evidence for DNA testing, which he claims will prove that he is innocent of the murders. After unsuccessfully filing two habeas corpus claims, Skinner filed a 42 U.S.C. § 1983 claim to attempt to gain access to the evidence. The Fifth Circuit denied Skinner’s motion to stay his execution, but Skinner appealed that decision and the Supreme Court agreed to hear Skinner’s case. The Court must now decide whether a demand for access to biological evidence may be brought under 42 U.S.C. § 1983, or whether the claim falls within the realm of habeas corpus law and was thus improperly filed. The Supreme Court’s decision will not only decide Skinner’s fate, but also clarify the scope and procedure of habeas corpus claims.

Oral argument: Oct. 12, 2010

Appealed from: United States Court of Appeals for the Ninth Circuit (Aug. 10, 2009)

HABEAS CORPUS, EXPERT TESTIMONY, AEDPA

Joshua Richter, convicted of murder, alleged that he received inadequate assistance from his attorney at trial. Richter argued that his attorney should have presented expert testimony concerning a blood splatter at the crime scene, which could have corroborated his version of the events. The United States Court of Appeals for the Ninth Circuit agreed with Richter and granted his request for habeas corpus relief. Kelly Harrington, the prison warden, claimed that Richter did not receive inadequate counsel and that the California Supreme Court’s earlier summary disposition denying habeas corpus relief should be upheld. The Supreme Court’s decision in this case will determine the level of deference that should be granted to lower court orders, such as summary dispositions, which could discourage lower courts from issuing such orders in the future.

Appealed from the United States Court of Appeals for the Sixth Circuit (March 10, 2009)

Oral argument: March 29, 2010

AEDPA, DOUBLE JEOPARDY, HABEAS CORPUS, MISTRIAL, MANIFEST NECESSITY, FIFTH AMENDMENT

Reginald Lett was convicted of second-degree murder in a Michigan state court in his second trial for the same offense. In his first trial, the judge determined that the jury was deadlocked and declared it a mistrial. Lett then filed a petition for a writ of habeas corpus in the Federal District Court for the Eastern District of Michigan. His petition was granted. On appeal, the Sixth Circuit Court of Appeals affirmed the district court’s ruling on the basis that Lett’s Fifth Amendment right to be free from Double Jeopardy had been violated because the trial court had not used “sound discretion” in finding a “manifest necessity” to declare a mistrial and terminate the ongoing proceedings. This case presents the Supreme Court with the opportunity to clearly articulate what state courts must do before declaring a mistrial to avoid running afoul of the Fifth Amendment.

Oral argument: Jan. 20, 2010

Appealed from: United States Court of Appeals for the Sixth Circuit (Sep. 24, 2008)

SIXTH AMENDMENT, HABEAS CORPUS, IMPARTIAL JURY

In 1993, an all-white jury convicted Diapolis Smith of second-degree murder and possession of a firearm during a felony. A 1990 Census showed that African-Americans comprised 7.8% of eligible jurors in the relevant county and 18.1% of eligible jurors in the relevant city. Smith challenged the county's system of jury selection, arguing it violated his Sixth Amendment right to a jury drawn from a fair-cross-section of the community. The Sixth Circuit ruled in his favor, rejecting Petitioner Mary Berghuis’ proposed “absolute-disparity test,” which subtracts the percentage of adult members of a distinct group in the venire from the percentage of eligible jurors of that distinct group in the population. It instead applied the “comparative-disparity test,” which divides the absolute-disparity by the percentage of the distinct group in the community. The Supreme Court’s decision may impact the composition of juries.

Oral argument: Nov. 4, 2009

Appealed from: United States Court of Appeals for the Eleventh Circuit (Sept. 16, 2008)

HABEAS CORPUS, DEATH PENALTY, ANTI-TERRORISM AND EFFECTIVE DEATH PENALTY ACT, AEDPA, SIXTH AMENDMENT, INEFFECTIVE ASSISTANCE OF COUNSEL

In 1994, Petitioner Holly Wood was convicted of capital murder for sneaking into his ex-girlfriend’s bedroom and shooting her in the head with a shotgun. The judge imposed the death penalty, as recommended by the jury. Wood claims that, during sentencing, he did not receive effective assistance of counsel as guaranteed by the Sixth Amendment. He argues that defense counsel failed to further investigate or present evidence of his mental disabilities. According to Wood, the state court’s rejection of this argument was an unreasonable application of federal law. He also argues that the Eleventh Circuit’s standard of review in habeas corpus proceedings abdicates the court’s judicial review function under the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”). The State of Alabama counters that the Eleventh Circuit properly deferred to the reasonable determinations of the state courts as required by the AEDPA. This decision will better define the appropriate level of deference due to state court factual determinations during federal habeas corpus proceedings.

Oral argument: Nov. 2, 2009

Appealed from: United States Court of Appeals for the Third Circuit (Sept. 3, 2008)

HABEAS CORPUS, ADEQUATE STATE GROUNDS DOCTRINE, FUGITIVE, DISCRETIONARY REVIEW

Joseph Kindler was convicted and sentenced to death by a Pennsylvania court for murder. While Kindler’s post-conviction motions were pending, he escaped and remained at large for years. The court then decided on the basis of a discretionally applied fugitive forfeiture rule that Kindler had waived his rights to make these motions when he fled. After Kindler was returned, he moved to reinstate his motions. The Pennsylvania courts denied this motion and Kindler subsequently petitioned the federal court for habeas review, which the district court granted and the circuit court affirmed. In this case the Supreme Court will decide if a federal court may grant a habeas petition when Pennsylvania’s highest court declared that Kindler forfeited his relief claims when he fled. Pennsylvania argues that its fugitive forfeiture rule is an adequate state ground that bars federal review. Kindler, however, claims the discretionally applied fugitive forfeiture rule was not applied with sufficient consistency in Pennsylvania courts to preclude habeas review.