Lujan v. Garcia, No. 10-55637 (9th Cir. 2013)
Annotate this CasePetitioner, convicted of two counts of first-degree murder, petitioned for federal habeas corpus relief under 28 U.S.C. 2254. The California Court of Appeal had found that the custodial confession at issue was obtained in violation of Miranda v. Arizona, but that it was harmless error. The district court conditionally granted the petition, finding that the California Court of Appeal's harmless error determination conflicted with the clearly established Supreme Court precedent of Harrison v. United States. Harrison held that when a defendant's trial testimony was induced by the erroneous admission of a confession into evidence, the trial testimony could not be introduced in a subsequent prosecution, nor could it be used to support the initial conviction on harmless error review. Harrison outlined a clear exclusionary rule that applied to the States; Harrison did not conflict with Motes v. United States; and Harrison remained clearly established law subsequent to Oregon v. Elstad. Accordingly, the court affirmed the district court's determination that federal habeas corpus relief under section 2254(d)(1) was warranted. The court affirmed the district court's and state appellate court's conclusion that law enforcement's communications with petitioner did not comply with the clearly established Supreme Court precedent in Miranda v. Arizona and its progeny. The court vacated portions of the district court's order and judgment that concluded second-degree murder convictions were an appropriate remedy, remanding to the district court to issue a conditional writ.
Court Description: Habeas Corpus. The panel affirmed in part and vacated in part the district court’s conditional grant of a 28 U.S.C. § 2254 habeas corpus petition based on a violation of Miranda v. Arizona, 384 U.S. 436 (1966). Petitioner confessed to two murders in a custodial interview during which he was not advised of his right to counsel before and during questioning. The panel held that petitioner’s rights under Miranda v. Arizona, 384 U.S. 436 (1966), were violated, because the words used by law enforcement during the custodial interview did not reasonably convey to petitioner that he had the right to speak with an attorney present at all times—before and during his custodial interrogations. Petitioner also confessed during his trial testimony. The panel held that the state court decision upholding the conviction, based on harmless error, violated Harrison v. United States, 392 U.S. 219 (1968), which in turn held that when a defendant’s trial testimony is induced by the erroneous admission of a confession into evidence, the trial testimony cannot be introduced in a subsequent prosecution, nor can it be used to support the initial conviction on harmless error review, because that would perpetuate the underlying constitutional error in the procurement of the confession. The panel vacated the portion of the district court’s order and judgment concluding that second-degree murder convictions are an appropriate remedy (based on the evidence after exclusion of the confessions), and remanded with instructions that the district court may offer the option that the state court make an independent determination as to whether the convictions can be modified under state law. The panel declined to address petitioner’s contention that the confession was involuntary, because this inquiry was neither appropriate nor necessary in light of the grant of habeas relief.
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