Jones v. Davis, No. 14-56373 (9th Cir. 2015)
Annotate this CaseThe State appealed the district court's grant of petitioner's habeas petition. Petitioner argued that California’s post-conviction system of judicial review creates such a long period of delay between sentencing and execution that only an “arbitrary” few prisoners actually are executed, in violation of the Eighth Amendment’s prohibition against cruel and unusual punishment. Under Teague v. Lane, federal courts may not consider novel constitutional theories on habeas review. The court concluded that, in this case, petitioner's claim asks the court to apply a novel constitutional rule and therefore, the claim is barred by Teague. Accordingly, the court reversed the district court's judgment.
Court Description: Habeas Corpus / Death Penalty. The panel reversed the district court’s judgment granting relief on a capital petitioner’s claim that California’s post- conviction system of judicial review violates the Eighth Amendment’s prohibition against cruel and unusual punishment by creating excessive delay between sentencing and execution, such that only an arbitrary few prisoners are executed. The panel held that this court has discretion to deny a claim as barred by Teague v. Lane, under which federal courts may not consider novel constitutional theories on habeas review, without considering the parties’ arguments concerning exhaustion. The panel held that the petitioner’s claim seeks to apply a novel constitutional rule, and is therefore barred by Teague. Concurring in the judgment, Judge Watford wrote that the rule announced by the district court is substantive rather than procedural and is therefore not precluded by Teague. He would reverse the judgment on the ground that the petitioner’s claim remains unexhausted. JONES V. DAVIS 3
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