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.