Murdaugh v. Ryan, No. 10-99020 (9th Cir. 2013)
Annotate this CasePetitioner, convicted of murder and sentenced to death, appealed the denial of his federal habeas petition. Because the existence or absence of mitigating circumstances directly affected whether petitioner was death eligible under Arizona law, petitioner had a right to have a jury decide those facts under Ring v. Arizona. Applying the harmless error test, the court concluded that, in this instance, the absence of a jury at the sentencing stage had a substantial and injurious effect or influence on petitioner's sentence of death. Therefore, the court granted the habeas petition. Because the court reversed the denial of relief on the Ring claim, the court need not reach the claims concerning petitioner's competence to waive the presentation of mitigating evidence. The court otherwise affirmed and remanded with instructions to grant the petition unless the state court conducts a new sentencing hearing within a reasonable period of time.
Court Description: Habeas Corpus/Death Penalty. The panel reversed in part and affirmed in part the district court’s denial of a 28 U.S.C. § 2254 habeas corpus petition challenging a conviction and capital sentence for murder. The panel reversed the district court’s denial of relief as to petitioner Murdaugh’s claim of error under Ring v. Arizona, 536 U.S. 584 (2002), which requires a jury determination of the presence or absence of aggravating factors supporting the death penalty. After acknowledging that Ring error is subject to the harmless error test, the panel concluded that the Ring error had a substantial and injurious effect or influence on the trial court’s failure to find the mitigating factor regarding Murdaugh’s capacity to appreciate the wrongfulness of his conduct or conform it to the requirements of law, and thus on the trial court’s imposition of a death sentence. The panel explained that, had the state supreme court considered all of the evidence, it would have been impossible to conclude that no rational jury could have found this factor. Having granted relief as to this claim, the panel reserved judgment on Murdaugh’s claims about his competence to waive the presentation of mitigating evidence at sentencing. The panel otherwise affirmed the district court’s decision. The panel next held that the state court did not violate Murdaugh’s constitutional rights by applying an unconstitutional causal nexus test to mitigating evidence of his drug use and delusions. The panel also held that Murdaugh was not denied his right to conflict-free representation when the prosecutor presented mitigating evidence at the behest of the trial court after Murdaugh declined to present such evidence, because the prosecutor did not represent Murdaugh. The panel also denied relief as to Murdaugh’s challenges to his guilty plea.
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