Styers v. Ryan, No. 12-16952 (9th Cir. 2015)
Annotate this CasePetitioner was convicted of first degree murder and other charges and sentenced to death. This court subsequently found that the Arizona Supreme Court had erred in not considering certain mitigation evidence, because it found such evidence was not connected to petitioner’s actions at the time of the murder. The court reversed and remanded to the district court to issue a conditional writ ordering petitioner's release from his death sentence unless the State were to initiate proceedings either to correct the constitutional error or to vacate the death sentence and impose a lesser sentence. The district court so ordered and the state court affirmed the death sentence. Petitioner then moved the district court for an unconditional writ of habeas corpus, arguing that the Arizona Supreme Court was powerless to correct the constitutional error, because the law had changed since Styers I. Petitioner made a Ring v. Arizona claim before the state court, arguing that the conditional writ of habeas corpus required that petitioner be re-sentenced and that a jury must find the aggravating factors rendering him eligible for the death penalty. The state court denied the claim on the ground that petitioner's sentence was final. The U.S. Supreme Court has never held that the issuance of a conditional writ of habeas corpus necessarily renders non-final a conviction or sentence that was predicated on constitutional error, and the conditional writ of habeas corpus in this case did not vacate petitioner’s death sentence. Therefore, the court concluded that the state court's determination that petitioner's sentence remained final at the time of the second independent review was not contrary to federal law as determined by the Supreme Court of the United States. Finally, the state court considered the mitigating evidence and decided to give it little weight. Neither Tennard v. Dretke, nor Eddings v. Oklahoma, requires more. Accordingly, the court affirmed the judgment.
Court Description: Habeas Corpus. The panel affirmed the district court’s denial of James Lynn Styers’s motion for an unconditional writ of habeas corpus after the Arizona Supreme Court, in response to the district court’s conditional writ ordered by this court in Styers v. Schriro, 547 F.3d 1028 (9th Cir. 2008), conducted an independent review of Styers’s death sentence, and affirmed it in 2011. In Styers, this court held that when the Arizona Supreme Court initially affirmed the death sentence in 1993, it violated Eddings v. Oklahoma, 455 U.S. 104 (1982), and Smith v. Texas, 453 U.S. 37 (2004), which prohibit consideration of only mitigation evidence causally related to the crime. Styers argued in his petition for the unconditional writ that, after the U.S. Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 (2002), the Arizona Supreme Court was powerless to correct the constitutional error identified in Styers, and that the death sentence could now be imposed only by a jury’s determination of the aggravating factors. The Arizona Supreme Court denied the Ring claim on the ground that the sentence was final. The panel observed that the U.S. Supreme Court has never held that the issuance of a conditional writ of habeas corpus necessarily renders non-final a conviction or sentence STYERS V. RYAN 3 that was predicated on constitutional error, and that the conditional writ in this case did not vacate Styers’s death sentence. The panel concluded that the Arizona Supreme Court’s determination that Styers’s sentence remained final at the time of the second independent review was therefore not contrary to federal law as determined by the U.S. Supreme Court. The panel rejected Styers’s contention that the Arizona Supreme Court failed to correct the error found by this court in Styers. The panel observed that the Arizona Supreme Court considered the mitigating evidence and decided to give it little weight, and that neither Tennard v. Dretke, 542 U.S. 274 (2004), nor Eddings requires more.
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