Rodriguez v. McDonald, No. 12-56594 (9th Cir. 2017)
Annotate this CaseThe Ninth Circuit reversed the district court's denial of a habeas corpus petition where petitioner challenged his conviction for second degree murder and attempted murder. Petitioner was fourteen years old at the time he was found guilty of the crimes. The panel held that the government relied on a coerced waiver of the right to counsel to secure the conviction because petitioner did not knowingly, intelligently, and voluntarily waive such right. Because admission of petitioner's confession was not harmless, the panel granted relief under 42 U.S.C. 2254.
Court Description: Habeas Corpus The panel reversed the district court’s judgment denying Jessie Rodriguez’s habeas corpus petition challenging his conviction for second-degree murder and attempted murder, and remanded, in a case in which Rodriguez, who was fourteen years old at the time detectives interviewed and arrested him, argued that his written confession was obtained in violation of Miranda v. Arizona. After reviewing the record available to the state courts, including a videotape of the interview and transcript of that videotape, the panel held that the California Court of Appeal’s determination that the detectives honored Rodriguez’s invocation of his right to counsel was unreasonable. Having concluded that the state court’s decision was based on an unreasonable determination of facts, the panel reviewed the legal issues de novo, and held that the government failed to meet its heavy burden of showing that Rodriguez’s subsequent waiver of his right to counsel was knowing, intelligent, and voluntary. The panel held that the admission of Rodriguez’s confession was not harmless, and that Rodriguez is therefore entitled to habeas relief.
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