Poyson v. Ryan, No. 10-99005 (9th Cir. 2018)
Annotate this CaseThe Ninth Circuit granted a petition for rehearing, filed an amended opinion reversing the denial of habeas relief challenging petitioner's death sentence, and remanded. The panel held that the Arizona Supreme Court denied petitioner his Eighth Amendment right to individualized sentencing by applying an unconstitutional causal nexus test to his mitigating evidence of a troubled childhood and mental health issues. Such error had a substantial and injurious effect or influence in determining the sentence. The panel denied habeas relief on petitioner's claim that the Arizona courts failed to consider his history of substance abuse as a nonstatutory mitigating factor. Finally, the panel agreed with the district court that petitioner's ineffective assistance of counsel claim was procedurally defaulted because it was fundamentally different from the claim he presented in state court.
Court Description: Habeas Corpus / Death Penalty. The panel granted a petition for panel rehearing, filed an amended opinion reversing the district court’s denial of Robert Allen Poyson’s habeas corpus petition challenging his death sentence, and remanded. The panel held that the Arizona Supreme Court denied Poyson his Eighth Amendment right to individualized sentencing by applying an unconstitutional causal nexus test to his mitigating evidence of a troubled childhood and mental health issues. The panel held that the error had substantial and injurious effect or influence in determining the sentence, and therefore granted habeas relief on this claim. The panel denied relief on Poyson’s claim that the Arizona courts failed to consider his history of substance abuse as a nonstatutory mitigating factor. The panel wrote that the state courts did consider the evidence and simply found it wanting as matter of fact. The panel wrote that the state supreme court did not misconstrue the state trial court’s findings, so it did not deprive Poyson of meaningful appellate review of his death sentence. The panel agreed with the district court that Poyson’s ineffective assistance of counsel claim is procedurally defaulted because it is fundamentally different from the claim he presented in state court. POYSON V. RYAN 3 The panel denied Poyson’s motion for reconsideration of its March 2013 order denying his motion for remand under Martinez v. Ryan, 566 U.S. 1 (2012). Judge Ikuta concurred because the three-judge panel is bound by the decision in McKinney v. Ryan, 813 F.3d 798 (9th Cir. 2015) (en banc), but wrote separately to highlight how McKinney’s erroneous conclusion that a causal nexus error had a “substantial and injurious effect” on a state court’s decision infects the panel’s decision in this case.
This opinion or order relates to an opinion or order originally issued on March 22, 2013.
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.