fair trial

Issues

Mathew Musladin was convicted in California state court of the first-degree murder of his ex-wife’s fiancé, Tom Studer. During the trial, Studer’s family members wore large buttons, visible to the jury, bearing a photograph of Studer. Musladin appealed his conviction on the grounds that the buttons influenced the jury and eroded his presumption of innocence. When his appeal failed, Musladin filed a habeas corpus petition with the federal District Court, which was also rejected. Relying on another Ninth Circuit case, the Court of Appeals for the Ninth Circuit held that the District Court should have granted Musladin’s petition. Under the Antiterrorism and Effective Death Penalty Act (AEDPA), a federal court may only overturn a state court’s decision on habeas grounds if the state decision was contrary to or involved an unreasonable application of federal law as determined by the Supreme Court. Since the Ninth Circuit’s decision to overturn Musladin’s conviction relied heavily on Ninth Circuit case law, not a Supreme Court decision, the Supreme Court’s  decision in this case  will determine what role, if any, circuit court opinions can play in the interpretation of  federal  law under AEDPA.

Questions as Framed for the Court by the Parties

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On February 8, 2010, a magistrate judge held a hearing with the defendant, Anthony Davila, and his attorney. At the hearing, the judge encouraged Davila to plead guilty, and on May 11, 2010, Davila pled guilty to the charges. On appeal, Davila successfully argued that the judge’s encouragement constituted a violation of Federal Rules of Criminal Procedure (“FRCP”) 11(c)(1), which generally prohibits the judge from participating in plea-bargaining. The Supreme Court granted certiorari to determine whether any judicial participation in plea-bargaining, as opposed to “prejudicial” participation, mandates automatic reversal of a conviction. The United States argues that FRCP 11(h) requires the appellate court to review Rule 11 errors under the harmless error standard, while Davila counters that an 11(c)(1) error requires automatic reversal. Furthermore, the United States sees many 11(c)(1) violations as technical and harmless, while Davila views such violations as universally prejudicial, making the government’s role effectively redundant. Both Davila and the United States argue that a ruling for the other party will undermine the finality of guilty convictions secured by plea bargains.

Questions as Framed for the Court by the Parties

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The Sixth Amendment to the United States constitution provides:  “In all criminal prosecutions, the accused shall enjoy the right…to have the assistance of counsel for his defense.”  In Cuauhtémoc Gonzalez-Lopez’s criminal trial, the district court refused to allow Gonzalez-Lopez to hire the attorney of his choice.  On review, the Eighth Circuit held that this denial violated Gonzalez-Lopez’s Sixth Amendment right to proceed with the counsel of his choice. Gonzalez-Lopez argues that the Eighth Circuit’s holding that the district court violated his Sixth Amendment right should stand. The government argues that the Eighth Circuit’s ruling conflicts with the Supreme Court’s ‘right to counsel’ decisions, which hold that a criminal defendant cannot obtain reversal of his conviction unless he establishes that an alleged error implicating his Sixth Amendment right to counsel compromised his right to a fair trial.

Questions as Framed for the Court by the Parties