Smith v. Ryan, No. 14-99008 (9th Cir. 2016)
Annotate this CasePetitioner, convicted of two murders and sentenced to death, challenged the district court's denial of his habeas petition. The court concluded that the Arizona Supreme Court did not act unreasonably in rejecting petitioner’s Sixth Amendment confrontation claim where his argument is foreclosed by Williams v. New York, which held that the Confrontation Clause does not bar courts from considering unconfronted statements during sentencing proceedings; the court rejected petitioner's claims in relation to the prosecution's rebuttal evidence and concluded that the district court did not err in finding that he suffered no constitutional violation when the prosecution introduced substantial evidence of petitioner's prior crimes during the penalty-phase hearings; any (E)(2) vagueness challenge fails because both the trial court and Arizona Supreme Court applied the narrowed definition of the (E)(2) aggravator to petitioner’s case; the application of the (E)(2) aggravator was in no way contrary to or an unreasonable application of clearly established federal law; neither the state trial court’s decision to give the (E)(6) narrowing instruction, nor the Arizona Supreme Court’s (E)(6) analysis, was so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement; and petitioner's ineffective assistance of counsel claim was procedurally defaulted. Accordingly, the court affirmed the judgment.
Court Description: Habeas Corpus / Death Penalty. The panel affirmed the district court’s denial of Arizona state prisoner Joseph Clarence Smith’s 28 U.S.C. § 2254 habeas corpus petition challenging his death sentence, imposed at 2004 resentencing proceedings, for the murders of Sandy Spencer and Neva Lee. The panel held that Smith’s contention that the trial court’s admission of testimonial hearsay during the aggravation phase of resentencing proceedings violated his Sixth Amendment confrontation rights is foreclosed by Williams v. New York, 337 U.S. 241 (1949), which held that the Confrontation Clause does not bar courts from considering unconfronted statements during sentencing proceedings. The panel held that in light of Smith’s reliance on his sexual sadism diagnosis and the U.S. Supreme Court’s pronouncement that the prosecution enjoys wide latitude in admitting rebuttal evidence, it was reasonable for the Arizona Supreme Court to conclude that the prosecution’s introduction of substantial evidence of Smith’s prior crimes during the penalty-phase hearings fell within the boundaries of due process. The panel held that introduction of this rebuttal evidence did not violate the Eighth Amendment. The panel held that any change between Arizona’s 1970’s and 2003 capital sentencing statutes was procedural rather than SMITH V. RYAN 3 substantive, and that the state trial court’s rejection of Smith’s claim that admission of the rebuttal evidence during the 2004 penalty-phase hearings violated his rights under the Ex Post Facto Clause was therefore not contrary to nor an unreasonable application of Carmell v. Texas, 529 U.S. 513 (2000). The panel held that any vagueness challenge to the application of the Arizona (E)(2) aggravator (for a previous conviction for a felony involving the use or threat of violence on another person) fails because both the trial court and the Arizona Supreme Court applied the narrowed definition of the aggravator. The panel held that application of the (E)(2) aggravator to the facts of Smith’s case was not contrary to nor an unreasonable application of clearly established federal law. The panel held that the Arizona Supreme Court’s rejection of Smith’s argument that application of the Arizona (E)(6) aggravator (for offenses committed in an especially heinous, cruel, or depraved manner) violates the Eighth Amendment was not an unreasonable application of clearly established federal law. The panel held that because Smith cannot establish prejudice from counsel’s failure to obtain brain scans, his claim of ineffective assistance at his 2004 resentencing proceedings is not substantial, and his procedural default on that claim cannot be excused under Martinez v. Ryan, 132 S. Ct. 1309 (2012). 4 SMITH V. RYAN
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