insanity

Clark v. Arizona

Issues

Whether Arizona's insanity law, as set forth in A.R.S. § 13-502 (1996) and applied in this case, violated Petitioner's right to due process under the United States Constitution, Fourteenth Amendment?

Whether Arizona's blanket exclusion of evidence and refusal to consider mental disease or defect to rebut the state's evidence on the element of mens rea violated Petitioner's right to due process under the United States Constitution, Fourteenth Amendment?

 

 

On June 21, 2000, 17-year-old Eric Clark shot and killed Flagstaff, Arizona Police Officer Jeffrey Moritz. Brief for Petitioner at 2. At the time, Clark had been suffering from delusions and hallucinations and had been diagnosed as suffering schizophrenia and psychosis. Id. At trial, he attempted to present evidence of his mental illness in order to negate the mens rea knowledge and intent elements of first degree murder. The government, however, argued successfully that under Arizona's definition of insanity (A.R.S. § 13-502(A)) and State v. Mott, evidence of Clark's mental illness was impermissible to negate the mens rea of the crime. Clark was subsequently convicted of first degree murder. He appeals the conviction, arguing that preventing him from using evidence of his mental disease to negate the mens rea of the crime violates his Due Process rights under the Fourteenth Amendment.

Questions as Framed for the Court by the Parties

Whether Arizona's insanity law, as set forth in A.R.S. § 13-502 (1996) and applied in this case, violated Petitioner's right to due process under the United States Constitution, Fourteenth Amendment?

Whether Arizona's blanket exclusion of evidence and refusal to consider mental disease or defect to rebut the state's evidence on the element of mens rea violated Petitioner's right to due process under the United States Constitution, Fourteenth Amendment?

 

In the early morning on June 21, 2000, in Flagstaff, Arizona, 17-year-old Eric Clark borrowed the keys to his brother's truck while his brother was sleeping.

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Knowles v. Mirzayance

Issues

1. What is the proper application of the Supreme Court's test for ineffective assistance of counsel when the state court opinion summarily denies habeas relief but does not explain its reasoning, where the Antiterrorism and Effective Death Penalty Act of 1996 statutorily denies federal habeas relief unless the state court 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"?

2. Did the Ninth Circuit improperly substitute its own findings of fact for those of the district court?

 

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.

Questions as Framed for the Court by the Parties

Concluding that defense counsel was ineffective in advising petitioner to withdraw his not-guilty-by-reason-of-insanity plea, the Ninth Circuit Court of Appeals granted habeas relief to petitioner without analyzing the state-court adjudication deferentially under "clearly established" law as required by 28 U.S.C. § 2254(d) and by supplanting the district court's factual findings and credibility determinations with its own, opposite factual findings. This Court vacated the Ninth Circuit decision and remanded the case for further consideration in light of Carey v. Musladin, 127 S. Ct. 649 (2006). On remand, the Ninth Circuit conceded that "no Supreme Court case has specifically addressed a counsel's failure to advance the defendant's only affirmative defense" but nonetheless concluded that its original decision was "unaffected" by Musladin and subsequent § 2254(d) decisions of this Court.

The questions presented are:

1. Did the Ninth Circuit again exceed its authority under § 2254(d) by granting habeas relief without considering whether the state-court adjudication of the claim was "unreasonable" under "clearly established Federal law" based on its previous conclusion that trial counsel was required to proceed with an affirmative insanity defense because it was the only defense available and despite the absence of a Supreme Court decision addressing the point?

2. May a federal appellate court substitute its own factual findings and credibility determinations for those of a district court without determining whether the district court's findings were "clearly erroneous?"

The facts as presented here are drawn from the party briefs.

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