habeas corpus

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This case asks the Supreme Court to decide whether Federal Rule of Civil Procedure 60(b)(1), which authorizes relief from a final judgment on the grounds of “mistake, inadvertence, surprise, or excusable neglect,” authorizes relief on the grounds that a district court committed an error of law. A federal district court determined that petitioner Dexter Earl Kemp’s motion for relief from legal error under Rule 60(b)(6) should instead be construed as a motion under Rule 60(b)(1) and dismissed Kemp’s petition because it was not presented within the one-year limitations period that applies to motions under Rule 60(b)(1) but not to motions under Rule 60(b)(6). On appeal to the Supreme Court, Kemp argues that, because Rule 60(b)(1) replicated identical state statutory provisions that did not allow relief for legal error, the Court cannot construe Rule 60(b)(1) to authorize relief for legal error. The United States responds that both the plain meaning of Rule 60(b)(1) and the fact that Rule 60(b)(1) replicated a California statute allowing relief for legal error establish that Rule 60(b)(1) allows relief for legal error. Because the Court’s decision on the meaning of Rule 60(b)(1) will determine for how long after entry of final judgment a litigant is entitled to seek relief for legal error, the resolution of this case will affect the expediency and finality of federal civil litigation. 

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During his trial for first-degree murder, Alexandre Mirzayance's attorney advised him to withdraw his insanity plea on the morning the insanity phase of the trial was to begin. After he was sentenced to twenty-nine years to life, Mirzayance initiated a habeas petition, claiming that his attorney's advice to withdraw his insanity plea constituted ineffective assistance of counsel. The California Court of Appeals and the California Supreme Court both summarily dismissed the petition without explanation. Mirzayance appealed to the federal court system. Under the Antiterrorism and Effective Death Penalty Act ("AEDPA"), a federal court is barred from granting habeas relief unless the prior state proceeding "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." After a remand from the Ninth Circuit to conduct a factual hearing, the district court granted the petition, apparently misapprehending the test the Ninth Circuit dictated. The Ninth Circuit applied the facts surrounding the withdrawal of the defense and found ineffective assistance of counsel under the Strickland test. Knowles argues that the Ninth circuit failed to adhere to AEDPA's rule requiring deference to state courts. He argues that it should have reviewed the state-court decision based on whether there was any way that the state court could have ruled the way it did. Mirzayance argues that when a state court has no published reasoning for its decision, a federal court is entitled to conduct its own fact-finding on review.

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For a criminal defendant to appeal his conviction under a writ of habeas corpus, he must file a petition for relief with the district court within one year of the final resolution of state court appeal. An extension of this time is granted when there is an extraordinary circumstance justifying equitable tolling or if a statute authorizes it. Lawrence v. Florida asks the Supreme Court to determine whether a pending request for Supreme Court certiorari is 1) a statutory tolling event, 2) whether such a pending request for certiorari is an extraordinary event justifying equitable tolling, or 3) whether the delayed filing of a habeas petition by a state-assigned attorney is an extraordinary event justifying equitable tolling of the statute of limitations. The Supreme Court 's decision in this case will determine the availability of important post-conviction relief to indigent defendants affected by inconveniencing circumstances beyond their control.

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Upon receiving a state-court-issued death sentence, petitioner Cory Maples submitted a claim of ineffective assistance of counsel in post-conviction proceedings and petitioned for an evidentiary hearing. The court clerk took no action when two of three deliveries giving notice that the petition had been denied were returned because two of Maples’s attorneys of record had left their firm. Shortly thereafter, the deadline to submit a federal habeas claim lapsed. Maples now argues that the court clerk’s failure to notify him that his petition for an evidentiary hearing was denied caused the default and violated his due process rights. Additionally, he argues that the actions of his attorneys also constitute an external cause entitling him to federal habeas review. Respondent, the Commissioner of the Alabama Department of Corrections, argues that the clerk successfully notified one attorney of  record,  and that Supreme Court precedent places the risk of attorney error on the petitioner during the post-conviction phase. This decision could affect how much risk clients bear for poor attorney performance, and whether a court clerk’s failure to take additional steps to notify attorneys of record constitutes an external cause to the defendant and valid excuse for  procedural  default.

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In 1987, a California jury convicted Respondent Kenneth Clair of the murder of Linda Rodgers, sentencing him to death. Clair filed a habeas corpus petition requesting new court-appointed counsel in 1995, but the district court rejected his request. On appeal, the United States Court of Appeals for the Ninth Circuit overturned the district court’s decision, and remanded to allow Clair’s new attorney to present additional claims. Clair argues that the district court abused its discretion by not properly investigating Clair’s request for substitute counsel, and consequently that he (Clair) must be allowed to make new claims and present additional evidence in the interests of justice. The State of California, however, argues that Clair should not be permitted to circumvent the workings of the justice system by rearguing his case merely because of dissatisfaction with his court-appointed counsel. The Supreme Court’s decision will determine the standard courts use in granting requests from habeas petitioners for substitute counsel, as well as the finality of appellate denials of habeas petitions.

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Petitioner Luis Mariano Martinez, a convicted felon serving consecutive terms of 35 years to life, filed a writ of habeas corpus seeking relief in federal court. Martinez alleges that his trial counsel provided him with ineffective assistance. Because his appellate counsel failed to raise that ineffective-assistance claim in the first state post-conviction proceeding, an Arizona court precluded the claim on procedural grounds. The U.S. Court of Appeals for the Ninth Circuit ruled that Martinez did not have the right to counsel during his post-conviction proceeding, and concluded that he may not claim ineffective assistance at that stage in order to overcome his procedural default. Consequently, Martinez is barred from raising his ineffective-assistance-of-trial-counsel claim, regardless of whether his post-conviction counsel rendered him ineffective assistance and caused the procedural default that precluded his trial-level claim. Martinez argues that he has a constitutional right to effective assistance of post-conviction counsel in raising his ineffective-assistance-of-trial-counsel claim; he concludes that ineffective post-conviction counsel should negate the procedural default with respect to his ineffective-trial-counsel claim in this federal habeas proceeding. Respondent Charles L. Ryan, Director of the Arizona Department of Corrections, asserts that defendants do not have a right to counsel in post-conviction proceedings, concluding from this that the ineffective assistance of Martinez’s post-conviction counsel cannot negate his procedural default. In this decision, the Supreme Court will have to weigh the possibility that poorly-represented defendants will lose ineffective-assistance claims due to procedural defaults against the benefits of efficient state criminal proceedings.

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Following a state conviction for sexual assault, Troy Brown (“Brown”) filed a petition for writ of habeas corpus in the United States District Court for the District of Nevada. The District Court allowed Brown to present new evidence: a report from Dr. Lawrence Mueller. This report detailed a statistical error (“prosecutor’s fallacy”) made by the prosecution during the presentation of DNA evidence. Based on Dr. Mueller’s report, the District Court dismissed the DNA evidence from consideration, found insufficient evidence to convict Brown, and ordered a retrial. The Ninth Circuit affirmed. Petitioner, Warden E.K. McDaniel (“McDaniel”), argues that, under Jackson v. Virginia’s sufficiency-of-the-evidence standard, a district court may not supplement the trial record. Additionally, McDaniel asserts that the District Court’s analysis was not sufficiently deferential to the state court. Brown agrees with McDaniel that the Ninth Circuit improperly applied Jackson. Brown, however, argues that the lower courts analyzed his case as a due process violation, and, as such, a retrial is  the proper remedy  to correct flawed DNA evidence.

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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. 

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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.

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This case presents the Supreme Court with an opportunity to determine whether Miller v. Alabama’s prohibition of mandatory sentencing schemes requiring juveniles to be sentenced to life in prison without parole applies retroactively to offenders seeking collateral review. See  Brief for Petitioner, Henry Montgomery at i. Montgomery argues that Miller applies retroactively, because it announces a new substantive rule altering the range of available sentencing options, and it establishes a substantive right to individualized sentencing for juveniles facing life without parole. See id. at 16–19. However, Louisiana argues that Miller does not apply retroactively because it proscribes a procedural rather than a substantive rule. See Brief for Respondent, Louisiana at 16. The Court’s decision will impact the treatment of juveniles in sentencing proceedings.

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