WASHINGTON — In a pair of 5-to-4 decisions that divided along ideological lines, the Supreme Court on Tuesday made it easier for inmates to challenge their convictions.
In McQuiggin v. Perkins, No. 12-126, the majority said a one-year filing deadline for prisoners seeking federal review of their state court convictions under a 1996 law may be relaxed if they present compelling evidence of their innocence. The new “miscarriage of justice exception” to the deadline, Justice Ruth Bader Ginsburg wrote for the majority, “applies to a severely confined category” — cases in which no reasonable juror aware of the new evidence would have voted to convict the defendant.
The appeal was brought by Floyd Perkins, a Michigan man serving a life sentence for murder. He was convicted based largely on the testimony of Damarr Jones, who said he saw Mr. Perkins stab a third man in the head in 1993 after they left a house party in Flint. The third man, Rodney Henderson, was found dead on a wooded trail.
Mr. Perkins testified that he had parted from the other two men before the killing and later saw his accuser under a streetlight, bloody and agitated. The jury believed Mr. Jones.
While in prison, Mr. Perkins obtained sworn statements from three people who said they had evidence that Mr. Jones was the actual killer. Their basic contention was that Mr. Jones had taken a bloody pair of orange pants to a dry cleaner the day after the killing.
Though Mr. Perkins obtained the last statement in 2002, he did not ask a federal judge to throw out his conviction until 2008. The judge refused, saying that it had been filed too late, and that the statements were in any event “dubious.”
The United States Court of Appeals for the Sixth Circuit, in Cincinnati, reversed the judge’s ruling, saying that Mr. Perkins’s lack of diligence in presenting the new evidence did not matter. Justice Ginsburg said that was not quite right. Diligence, she wrote, was a factor in assessing the reliability of the new evidence.
Justice Ginsburg, even as she said that strong evidence of innocence may be considered at any time, indicated that she did not think much of Mr. Perkins’s efforts. Her opinion returned the case to the Sixth Circuit with instructions to adopt the trial court’s negative assessment of the statements Mr. Perkins had collected “absent cause, which we do not currently see, for the Sixth Circuit to upset that evaluation.” Justices Anthony M. Kennedy, Stephen G. Breyer, Sonia Sotomayor and Elena Kagan joined the majority opinion.
In dissent, Justice Scalia wrote that “there is not a whit of precedential support” for the idea that the Supreme Court was entitled to alter the deadline set out in the 1996 law. Chief Justice John G. Roberts Jr. and Justice Clarence Thomas joined all of the dissent, and Justice Samuel A. Alito Jr. joined most of it.
Justice Ginsburg dismissed the dissent as “bluster.”
In the second decision issued Tuesday, in Trevino v. Thaler, No. 11-10189, the same five-justice majority extended a ruling last year that had allowed prisoners to challenge their state convictions in federal courts based on the argument that their trial lawyers had been ineffective, even though the prisoners had not raised the issue in earlier proceedings.
In the decision last year, in Martinez v. Ryan, a seven-justice majority considered Arizona’s criminal justice system, which required claims of ineffective assistance of counsel to be raised in a separate state post-conviction challenge, in which there is no right to a lawyer, and not in the direct appeal from the conviction, in which there is. The Supreme Court ruled that federal courts may hear challenges to Arizona convictions based on claims of ineffective assistance at trial if the prisoner had no lawyer in the separate proceeding or if that lawyer was also ineffective.
“By deliberately choosing to move trial-ineffectiveness claims outside the direct-appeal process, where counsel is constitutionally guaranteed, the state significantly diminishes prisoners’ ability to file such claims,” Justice Kennedy wrote for the majority in the Martinez decision.
The new case considered Texas’ system, which appears to encourage but not require that such claims be raised in a separate proceeding. Justice Breyer, writing for the majority, said that difference did not matter. “What the Arizona law prohibited by explicit terms,” he wrote, “Texas precludes as a matter of course.”
In dissent, Chief Justice Roberts said the Martinez decision had announced a “crisp limit.” “But today,” he added, “the court takes all the starch out of its rule with an assortment of adjectives, adverbs and modifying clauses.” Chief Justice Roberts had voted with the majority in Martinez, as had Justice Alito, who joined the chief justice’s dissent Tuesday.
The two dissenters in Martinez, Justices Scalia and Thomas, filed a separate dissent.
In another development Tuesday, in Secretary of the Indiana Family and Social Services Administration v. Planned Parenthood of Indiana, No. 12-1039, the court let stand without comment an appeals court ruling blocking an Indiana law that would have withheld Medicaid money from Planned Parenthood because it performs abortions.
No comments:
Post a Comment