Shinn v. Ramirez | |
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Argued December 8, 2021 Decided May 23, 2022 | |
Full case name | David Shinn, Director, Arizona Department of Corrections, Rehabilitation and Reentry, et al. v. David Martinez Ramirez and Barry Lee Jones |
Docket no. | 20-1009 |
Citations | 596 U.S. 366 ( more ) |
Argument | Oral argument |
Holding | |
Under 28 U.S.C. § 2254(e)(2), a federal habeas court may not conduct an evidentiary hearing or otherwise consider evidence beyond the state-court record based on the ineffective assistance of state postconviction counsel. | |
Court membership | |
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Case opinions | |
Majority | Thomas, joined by Roberts, Alito, Gorsuch, Kavanaugh, Barrett |
Dissent | Sotomayor, joined by Breyer, Kagan |
Laws applied | |
Antiterrorism and Effective Death Penalty Act of 1996 |
Shinn v. Ramirez, 596 U.S. 366 (2022), was a case decided by the United States Supreme Court related to the Antiterrorism and Effective Death Penalty Act of 1996. The court held that new evidence that was not in the state court's records, based on ineffective assistance of post-conviction counsel, could not be used in an appeal to a federal court.
David Ramirez and Barry Jones were convicted of murders in Arizona and sentenced to death in 1989 and 1994, respectively. Ramirez appealed to federal court where his federal public defenders uncovered evidence of intellectual disability and extensive childhood abuse that hadn't been presented at his initial trial. Jones also appealed to federal court, where federal investigators found evidence suggesting he was innocent. In both cases, the new lawyers argued that the failure of the initial public defenders to present evidence that could have been mitigating constituted ineffective counsel. [1]
In Martinez v. Ryan (2012), the Supreme Court held that prisoners may use post-conviction counsel's ineffectiveness as a reason to overcome procedural default. The United States Court of Appeals for the Ninth Circuit applied Martinez to rule for Ramirez and Jones on their habeas corpus petitions. The Court denied rehearing en banc over the dissent of Judge Daniel P. Collins and seven other judges. Arizona filed a petition for a writ of certiorari. [2]
Certiorari was granted in the case on May 17, 2021. On May 23, 2022, the Supreme Court reversed the Ninth Circuit in a 6–3 opinion.
The majority opinion was authored by Clarence Thomas, and joined by John Roberts, Samuel Alito, Neil Gorsuch, Brett Kavanaugh, and Amy Coney Barrett, the court's six conservative justices. [3] Thomas stated that allowing claims, like the ones in this case, would cause delays in the future, and cited the brutality of the crimes that were committed. [4] He also cited a dissent written by the late Justice Antonin Scalia in Martinez, and another dissenting opinion written by Roberts in Trevino v. Thaler (2013), a case that applied Martinez. [3]
The dissenting opinion was authored by Sonia Sotomayor, and joined by Elena Kagan and Stephen Breyer, the court's three liberal justices. [5] She described the decision as "perverse" and "illogical". [6] Sotomayor also attacked the majority opinion's citations of previous dissenting opinions to back up its reasoning. She also hinted that doing so could make the Supreme Court's decision making process appear illegitimate. [3]
The Supreme Court of the United States handed down sixteen per curiam opinions during its 2005 term, which lasted from October 3, 2005, until October 1, 2006.
The Supreme Court of the United States handed down nineteen per curiam opinions during its 2009 term, which began on October 5, 2009, and concluded October 3, 2010.
Skinner v. Switzer, 562 U.S. 521 (2011), is a decision by the U.S. Supreme Court regarding the route through which a prisoner may obtain biological DNA material for testing to challenge his conviction; whether through a civil rights suit or a habeas corpus petition. A majority of the Court held that the civil rights path was the appropriate path.
Davis v. Ayala, 576 U.S. 257 (2015), was a case in which the Supreme Court of the United States upheld a death sentence of a Hispanic defendant despite the fact that all Blacks and Hispanics were rejected from the jury during the defendant's trial. The case involved a habeas corpus petition submitted by Hector Ayala, who was arrested and tried in the late 1980s for the alleged murder of three individuals during an attempted robbery of an automobile body shop in San Diego, California in April 1985. At trial, the prosecution used peremptory challenges to strike all Black and Hispanic jurors who were available for jury service. The trial court judge allowed the prosecution to explain the basis for the peremptory challenges outside the presence of Ayala's counsel, "so as not to disclose trial strategy". Ayala was ultimately sentenced to death, but he filed several appeals challenging the constitutionality of the trial court's decision to exclude his counsel from the hearings.
Kansas v. Carr, 577 U.S. 108 (2016), was a case in which the Supreme Court of the United States clarified several procedures for sentencing defendants in capital cases. Specifically, the Court held that judges are not required to affirmatively instruct juries about the burden of proof for establishing mitigating evidence, and that joint trials of capital defendants "are often preferable when the joined defendants’ criminal conduct arises out of a single chain of events". This case included the last majority opinion written by Justice Antonin Scalia before his death in February 2016.
Ocasio v. United States, 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court clarified whether the Hobbs Act's definition of conspiracy to commit extortion only includes attempts to acquire property from someone who is not a member of the conspiracy. The case arose when Samuel Ocasio, a former Baltimore, Maryland police officer, was indicted for participating in a kickback scheme with an automobile repair shop where officers would refer drivers of damaged vehicles to the shop in exchange for cash payments. Ocasio argued that he should not be found guilty of conspiring to commit extortion because the only property that was exchanged in the scheme was transferred from one member of the conspiracy to another, and an individual cannot be found guilty of conspiring to extort a co-conspirator.
Foster v. Chatman, 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court held that the state law doctrine of res judicata does not preclude a Batson challenge against peremptory challenges if new evidence has emerged. The Court held the state courts' Batson analysis was subject to federal jurisdiction because "[w]hen application of a state law bar 'depends on a federal constitutional ruling, the state-law prong of the court’s holding is not independent of federal law, and our jurisdiction is not precluded,'" under Ake v. Oklahoma.
Utah v. Strieff, 579 U.S. 232, 136 S. Ct. 2056 (2016), was a case in which the Supreme Court of the United States limited the scope of the Fourth Amendment's exclusionary rule.
Bell v. Cone, 535 U.S. 685 (2002), was a Supreme Court of the United States case that upheld a death sentence despite the defendant's argument that he should not be sentenced to death because he was suffering from drug-induced psychosis when he committed the crimes. Cone also argued that he was denied effective assistance of counsel because his attorney failed to present sufficient mitigating evidence during the sentencing phase of his trial and that his attorney inappropriately waived his final argument during the sentencing phase. In an 8–1 opinion written by Chief Justice William Rehnquist, the United States Supreme Court denied Cone's petition for a writ of habeas corpus. The Court held that the actions taken by Cone's attorney during the sentencing phase were "tactical decisions" and that the state courts that denied Cone's appeals did not unreasonably apply clearly established law. Justice John Paul Stevens wrote a dissenting opinion in which he argued that Cone was denied effective assistance of counsel because his attorney failed to "subject the prosecution's case to meaningful adversarial testing."
Lafler v. Cooper, 566 U.S. 156 (2012), was a United States Supreme Court case in which the Court clarified the Sixth Amendment standard for reversing convictions due to ineffective assistance of counsel during plea bargaining. The Court ruled that when a lawyer's ineffective assistance leads to the rejection of a plea agreement, a defendant is entitled to relief if the outcome of the plea process would have been different with competent advice. In such cases, the Court ruled that the Sixth Amendment requires the trial judge to exercise discretion to determine an appropriate remedy.
Nieves v. Bartlett, 587 U.S. 391 (2019), was a civil rights case in which the Supreme Court of the United States decided that probable cause should generally defeat a retaliatory arrest claim brought under the First Amendment, unless officers under the circumstances would typically exercise their discretion not to make an arrest.
Department of Homeland Security v. Thuraissigiam, 591 U.S. ___ (2020), was a United States Supreme Court case involving whether the Illegal Immigration Reform and Immigrant Responsibility Act of 1996, which limits habeas corpus judicial review of the decisions of immigration officers, violates the Suspension Clause of Article One of the U.S. Constitution. In the 7–2 opinion, the Court ruled that the law does not violate the Suspension Clause.
City of Austin v. Reagan National Advertising of Austin, LLC, 596 U.S. ___ (2022), was a United States Supreme Court case dealing with the application of zoning restrictions on digital billboards in the city of Austin, Texas. In a 6–3 ruling, the Court ruled that the Austin regulation against off-premise digital signs was content-neutral and thus should be reviewed as a facial challenge rather than a strict scrutiny following from the reasoning in Reed v. Town of Gilbert.
Egbert v. Boule, 596 U.S. 482 (2022), is a United States Supreme Court case in which the court declined to extend Bivens v. Six Unknown Named Agents.
Shoop v. Twyford, 596 U.S. ___ (2022), was a United States Supreme Court case related to death row inmates' habeas corpus petitions.
Martinez v. Ryan, 566 U.S. 1 (2012), was a United States Supreme Court case which considered whether criminal defendants ever have a right to the effective assistance of counsel in collateral state post-conviction proceedings. The Court held that a procedural default will not bar a federal habeas court from hearing ineffective-assistance-of-trial-counsel if there was no counsel or ineffective counsel in an initial-review collateral proceeding.
Garland v. Gonzalez, 596 U.S. ___ (2022), was a United States Supreme Court case related to immigration detention.
Johnson v. Arteaga-Martinez, 596 U.S. ___ (2022), was a United States Supreme Court case related to immigration detention.
Cullen v. Pinholster, 563 U.S. 170, is a 2011 United States Supreme Court case concerning evidentiary development in federal habeas corpus proceedings. Oral arguments in the case took place on November 9, 2010, and the Supreme Court issued its decision on April 4, 2011. The Supreme Court held 5–4 that only evidence originally presented before the state court in which the claim was originally adjudicated on the merits could be presented when raising a claim under 28 U.S.C. § 2254(d)(1), and that evidence from a federal habeas court could not be presented in such proceedings. It also held that the convicted murderer Scott Pinholster, the respondent in the case, was not entitled to the habeas relief he had been granted by the United States Court of Appeals for the Ninth Circuit.
Schriro v. Landrigan, 550 U.S. 465 (2007), was a United States Supreme Court case decided on May 14, 2007. In a 5–4 decision written by Justice Clarence Thomas, the Court held that the District Court had not abused its discretion when it refused to grant an evidentiary hearing to convicted murderer Jeffrey Timothy Landrigan. In doing so, the Supreme Court also reversed the prior ruling to the contrary by the en banc United States Court of Appeals for the Ninth Circuit, which had held that Landrigan was entitled to habeas relief on the grounds that he had received ineffective assistance of counsel. The latter court had also held that the District Court's denial of such a hearing to Landrigan amounted to an "unreasonable determination of the facts", which is one of the two circumstances under which the Antiterrorism and Effective Death Penalty Act of 1996 permits the granting of federal habeas relief to state prisoners. The Supreme Court's decision also found that a criminal defendant could waive the right for their lawyer to present mitigating evidence on their behalf, and that such a waiver did not have to be "knowing and intelligent" in order to be valid, even in a capital case.
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