Spreitz v. Ryan, No. 09-99006 (9th Cir. 2019)
Annotate this Case
The Ninth Circuit reversed the district court's denial of habeas corpus relief to petitioner, who was convicted of first degree murder and sentenced to death. Petitioner argued that the Arizona Supreme Court unconstitutionally affirmed his death sentence by failing to consider mitigating evidence of his longstanding alcohol and substance abuse.
The panel held that the Arizona Supreme Court's decision was contrary to clearly established Supreme Court precedent. The panel held that the Arizona Supreme Court violated Eddings v. Oklahoma, 455 U.S. 104 (1982), by impermissibly requiring that petitioner establish a causal connection between his longstanding substance abuse and the murder before considering and weighing the evidence as a nonstatutory mitigating factor. Because the error was not harmless, the panel reversed the district court's judgment with respect to petitioner's death sentence.
Court Description: Habeas Corpus / Death Penalty. The panel reversed the district court’s denial of habeas corpus relief with respect to Christopher J. Spreitz’s death sentence, and remanded, in a case in which Spreitz argued that the Arizona Supreme Court violated Eddings v. Oklahoma, 455 U.S. 104 (1982), by refusing to consider, as a matter of law, mitigating evidence of Spreitz’s longstanding alcohol and substance abuse on the ground that he did not establish a causal connection between this mitigating evidence and the crime. The panel held that the district court erred in concluding that Spreitz’s claim that the Arizona Supreme Court violated Eddings is procedurally defaulted. The panel explained that the first opportunity Spreitz had to raise that claim was before the post-conviction-relief (PCR) court, at which time he did so. Because the decision of the PCR court – which first declared the claim waived, but proceeded to adjudicate the claim on the merits – was contrary to clearly established Supreme Court precedent, the panel accorded that decision no deference and reviewed Spreitz’s Eddings claim de novo. The panel concluded that the Arizona Supreme Court violated Eddings by impermissibly requiring that Spreitz establish a causal connection between his longstanding substance abuse and the murder before considering and
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.