Benson v. Chappell, No. 13-99004 (9th Cir. 2020)
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The Ninth Circuit affirmed the district court's denial of petitioner's habeas corpus petition challenging his California conviction and death sentence for murder and other crimes. Petitioner raised two certified claims and two uncertified claims.
The panel held that petitioner failed to show that the California Supreme Court's denials of his claims were unreasonable determinations of the facts or contrary to clearly established federal law. In this case, the California Supreme Court reasonably determined that an officer's misstatement during petitioner's interrogation that there was no death penalty in California did not prompt petitioner's confessions. Furthermore, petitioner failed to show that his statements were not knowing, voluntary, and intelligent. Even if petitioner were able to show that trial counsel was ineffective in not fully investigating his abuse as a child or his alleged organic brain injury, the panel held that the state court could reasonably have determined that any shortcoming in trial counsel's investigation was not prejudicial. Finally, the panel granted a certificate of appealability on petitioner's two uncertified claims and held that the state court reasonably rejected the claims that his trial counsel should have impeached the government's case and the prosecutor withheld material, exculpatory evidence.
Court Description: Habeas Corpus / Death Penalty. The panel affirmed the district court’s denial of Richard Allen Benson’s habeas corpus petition challenging his California conviction and death sentence for murder and other crimes. Benson raised two certified claims on appeal: (1) that his confessions should have been suppressed, and (2) that his trial counsel was ineffective at sentencing. Reviewing under the Antiterrorism and Effective Death Penalty Act, the panel held that Benson did not show that the California Supreme Court’s denials of his claims were unreasonable determinations of the facts or contrary to clearly established federal law. Observing that – as Benson admits – he confessed after he was given his Miranda warnings, acknowledged the warnings, and waived them, the panel held that the California Supreme Court reasonably determined that an officer’s misstatement during Benson’s interrogation that there was no death penalty in California did not prompt Benson’s confessions; and that Benson did not show that his statements were not knowing, voluntary, and intelligent. The panel held that even if Benson were able to show that trial counsel was ineffective in not fully investigating his abuse as a child or his alleged organic brain injury, the California Supreme Court could reasonably have determined BENSON V. CHAPPELL 3 that any shortcoming in trial counsel’s investigation was not prejudicial. The panel granted a Certificate of Appealability on Benson’s two uncertified issues and determined that the state court reasonably rejected his claims that (1) his trial counsel was ineffective at the guilt phase of the trial, and (2) the prosecutor withheld material, exculpatory evidence. Concurring in the majority’s decision on the first certified issue and on the uncertified claims, Judge Murguia dissented from the majority’s opinion with respect to Benson’s penalty- phase ineffective-assistance claim. She wrote that significant and readily-available evidence that Benson was subjected to grotesque sexual and physical abuse, which was never discovered by Benson’s lawyer and never introduced at the penalty phase, has a substantial probability of convincing at least one juror to vote for life rather than death, and that the California Supreme Court’s conclusion to the contrary is fundamentally unreasonable.
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