Rhines v. Young, No. 16-3360 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of habeas relief for petitioner, who received the death sentence after being convicted of murder and burglary. The court held that the district court did not err in concluding that petitioner was not entitled to relief on this Fifth Amendment self-incrimination claim under the Antiterrorism and Effective Death Penalty Act (AEDPA); the state courts did not unreasonably apply Strickland v. Washington in concluding that trial counsels' penalty phase efforts were not constitutionally deficient and the court need not address whether the state courts unreasonably concluded that there was no Strickland prejudice; the district court did not abuse its discretion in denying petitioner's motion to stay the habeas proceedings and file a second amended petition; the state court did not unreasonably apply clearly established federal law applying the Ex Post Facto Clause by permitting the victim's mother to give impact evidence; the state court's decision to reject the claim of ineffective assistance of appellate counsel because Simmons v. South Carolina, 512 U.S. 154 (1994), did not apply was not contrary to or an unreasonable application of clearly established federal law; the jury found three valid aggravating circumstances that clearly encompassed the facts and circumstances supporting its additional depravity-of-mind finding; and the court denied the application to file a second or successive petition.
Court Description: Loken, Author, with Gruender and Kelly, Circuit Judges] Prisoner case - State Habeas. Death Penalty Matter. The South Dakota Supreme Court's determination that the warnings given Rhines after his arrest were adequate was an objectively reasonable application of Miranda; claims of ineffective assistance of counsel during the penalty phase of Rhines's trial rejected, as counsel had a reasonable basis for their strategic decision that an explanation of Rhines's history and the presentation of other witnesses would not have minimized the risk of the death penalty and might have opened the door to "bad acts" evidence counsel had managed to get excluded; the district court did not abuse its discretion by denying Rhines's motion to amend his petition and stay the matter so that he could pursue new, unexhausted claims; a habeas petitioner granted a limited stay to exhaust state post-conviction remedies who returns to federal court and requests another stay to exhaust additional claims is deliberately engaging in dilatory tactics and intentional delay that are completely at odds with AEDPA's purpose to reduce delays in capital cases; in any event, the new claims would have been procedurally barred under South Dakota law, and further exhaustion would have been futile; the South Dakota Supreme Court's decision that it was not error to permit the victim's mother to read a victim impact statement at sentencing was not an unreasonable application of clearly established law concerning the Ex Post Facto clause or a violation of defendant's due process rights; the South Dakota Supreme Court's decision that the trial judge did not err in declining to answer the jury's questions regarding the nature of a life sentence was not an unreasonable application of clearly established federal law; the jury found three valid aggravating factors and the South Dakota Supreme Court's invalidation of a fourth factor - depravity of mind - as constitutionally overbroad did not invalidate the death sentence; Rhines's request for permission to file a second or successive habeas is denied.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.