Poyson v. Ryan, No. 10-99005 (9th Cir. 2013)
Annotate this CasePetitioner, convicted of murder and sentenced to death, appealed the district court's denial of his habeas petition. The court held that petitioner's first two claims on appeal, that the Arizona courts applied an unconstitutional causal nexus test to mitigating evidence and the Arizona courts failed to consider mitigation evidence of his history of substance abuse, were without merit. The court held that petitioner's third claim, that his trial counsel provided ineffective assistance, was procedurally defaulted. Accordingly, the court affirmed the judgment.
Court Description: Habeas Corpus/Death Penalty. The panel affirmed the district court’s denial of a 28 U.S.C. § 2254 habeas corpus petition by an Arizona state prisoner challenging a conviction and capital sentence for murder. The panel first held that the Arizona Supreme Court did not deny petitioner his right to individualized sentencing by applying an unconstitutional causal nexus test to potentially mitigating evidence, because the panel could not presume a constitutional violation from an ambiguous record that did not reveal whether the court applied such a test as an unconstitutional screening mechanism or as a permissible means of determining the weight or significance of mitigating evidence. The panel next denied relief on petitioner’s claim that the Arizona courts failed to consider his history of substance abuse as a nonstatutory mitigating factor. The panel explained that the state courts considered the evidence and found it wanting as a matter of fact because it failed to prove a history of substance abuse, and that the state supreme court did not misconstrue the state trial court’s findings so as to deny petitioner of meaningful appellate review. Finally, the panel agreed with the district court that petitioner’s ineffective assistance of counsel claim is procedurally defaulted because it is fundamentally different from the claim presented in state court such that the state courts had no meaningful opportunity to consider it. Judge Thomas concurred in part, but dissented because he would hold that the state court unconstitutionally excluded mitigating evidence from consideration because it was not causally related to the crimes.
The court issued a subsequent related opinion or order on November 7, 2013.
The court issued a subsequent related opinion or order on April 2, 2014.
The court issued a subsequent related opinion or order on January 12, 2018.
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