Dixon v. Ryan, No. 16-99006 (9th Cir. 2019)
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The Ninth Circuit affirmed the district court's denial of a petition for habeas corpus relief challenging petitioner's Arizona state murder conviction and death penalty. Applying deferential review under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), the panel held that the district court properly held that petitioner's Sixth Amendment right to effective assistance of counsel was not violated when his trial counsel elected not to challenge petitioner's competency to waive counsel, despite counsel's knowledge that he had a history of mental health issues; the district court properly concluded that petitioner's due process rights were not violated by the state trial court's failure to hold a competency hearing sua sponte; and the district court properly held that the Arizona Supreme Court's opinion concluding that the trial court did not abuse its discretion in denying petitioner's final continuance motion was neither contrary to, nor an unreasonable application of, clearly established federal law.
The panel expanded the certificate of appealability (COA) to include the question of whether petitioner's constitutional rights were violated at trial through use of restraints, but affirmed the denial of the writ on that issue. The panel declined to expand the COA further.
Court Description: Habeas Corpus / Death Penalty. The panel affirmed the district court’s denial of Clarence Wayne Dixon’s habeas corpus petition challenging his Arizona state murder conviction and death penalty. The panel applied deferential review under the Antiterrorism and Effective Death Penalty Act of 1996. The panel held that the district court properly held that Dixon’s Sixth Amendment right to effective assistance of counsel was not violated when his trial counsel elected not to challenge Dixon’s competency to waive counsel, despite counsel’s knowledge that Dixon had a history of mental health issues. The panel held that the Arizona Superior Court’s denial of Dixon’s petition for post-conviction relief did not unreasonably apply Strickland v. Washington, 466 U.S. 668 (1984), and that the record demonstrates that the Arizona Superior Court did not rely on an unreasonable determination of the facts. The panel held that the district court properly concluded that Dixon’s due process rights were not violated by the state trial court’s failure to hold a competency hearing sua sponte. The panel held that the state post-conviction-relief court’s determination without a hearing that Dixon was competent to waive counsel and represent himself was not an unreasonable DIXON V. RYAN 3 determination of the facts, nor was it contrary to clearly established law. The panel held that the district court properly held that the Arizona Supreme Court’s opinion concluding that the trial court did not abuse its discretion in denying Dixon’s final request for a continuance was neither contrary to, nor an unreasonable application of, clearly established law; and did not rest on an unreasonable determination of the facts. The panel expanded the certificate of appealability to cover Dixon’s claim that his Sixth and Fourteenth Amendment rights were violated when he was shackled and subject to electronic restraints during the trial. As to that claim, the panel held that the Arizona Supreme Court’s determination that Dixon was not prejudiced because the jury did not see the restraints was neither an unreasonable determination of the facts nor an application of Deck v. Missouri, 544 U.S. 622 (2005), contrary to clearly established federal law. The panel held that in holding in the alternative that any error under Deck was harmless, the Arizona Supreme Court did not apply Chapman v. California, 386 U.S. 18 (1967), in an objectively unreasonable manner. The panel held that the Arizona Supreme Court’s factual conclusions regarding the visibility of the restraints were not unreasonable. The panel declined to expand the COA as to other issues. 4 DIXON V. RYAN
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