Schriro v. Landrigan

Schriro v. Landrigan,, was a United States Supreme Court case decided on May 14, 2007. In a 5–4 decision written by Justice Clarence Thomas, the Court held that the District Court had not abused its discretion when it refused to grant an evidentiary hearing to convicted murderer Jeffrey Timothy Landrigan. In doing so, the Supreme Court also reversed the prior ruling to the contrary by the en banc United States Court of Appeals for the Ninth Circuit, which had held that Landrigan was entitled to habeas relief on the grounds that he had received ineffective assistance of counsel. The latter court had also held that the District Court's denial of such a hearing to Landrigan amounted to an "unreasonable determination of the facts", which is one of the two circumstances under which the Antiterrorism and Effective Death Penalty Act of 1996 permits the granting of federal habeas relief to state prisoners. The Supreme Court's decision also found that a criminal defendant could waive the right for their lawyer to present mitigating evidence on their behalf, and that such a waiver did not have to be "knowing and intelligent" in order to be valid, even in a capital case.

Background
Jeffrey Timothy Landrigan was convicted of second-degree murder in Oklahoma in 1982. In 1986, while in prison for that murder, Landrigan repeatedly stabbed another inmate, for which he was convicted of assault and battery with a deadly weapon. In 1989, he escaped from prison and murdered Chester Dean Dyer during a burglary. For this crime, Landrigan was convicted of theft, second-degree burglary, and felony murder. At his sentencing hearing for this conviction, Landrigan's lawyer attempted to present mitigating evidence, but Landrigan repeatedly interrupted him, and at Landrigan's request, multiple witnesses who had intended to testify on his behalf did not do so. The judge overseeing Landrigan's sentencing hearing subsequently sentenced him to death, and the Arizona Supreme Court unanimously affirmed his sentence and conviction.

After Landrigan's subsequent attempts to seek postconviction relief in state court failed, he filed a habeas corpus petition in federal court. The District Court refused to grant Landrigan an evidentiary hearing. On appeal, a three-judge panel of the Ninth Circuit affirmed this decision, but the full Ninth Circuit subsequently reheard the case en banc and reversed, holding that Landrigan was entitled to a hearing because, contrary to the District Court's conclusion, he had made a "colorable" claim that he had received ineffective assistance of counsel that fell below the standard outlined by the Supreme Court in Strickland v. Washington. The en banc Ninth Circuit stated that Landrigan's counsel had failed to adequately prepare for Landrigan's sentencing hearing, and that the Arizona postconviction court's conclusion that Landrigan had instructed his counsel not to present mitigating evidence was an "unreasonable determination of the facts" and thus grounds for habeas relief under AEDPA.

Supreme Court
The Supreme Court granted certiorari in the case on September 26, 2006. Oral arguments took place on January 9, 2007, and the Supreme Court issued its decision on May 14, 2007. Justice Clarence Thomas delivered the majority opinion, in which Chief Justice John Roberts, Antonin Scalia, Anthony Kennedy, and Samuel Alito joined. The Court reversed the en banc Ninth Circuit, holding that the District Court was entirely justified in refusing to grant him an evidentiary hearing, as well as in concluding that, even if he were permitted to further develop the factual record at such a hearing, he would still not be entitled to habeas relief. The majority opinion stated that "if the record refutes the applicant’s factual allegations or otherwise precludes habeas relief, a district court is not required to hold an evidentiary hearing."

The dissenting opinion was written by Justice John Paul Stevens and joined by David Souter, Ruth Bader Ginsburg, and Stephen Breyer. Stevens argued that Landrigan's counsel failed to adequately investigate and present mitigating evidence regarding Landrigan's upbringing and psychological condition. He also argued that the majority engaged in "pure guesswork" by reasoning that, were they to grant Landrigan an evidentiary hearing, it would not have made a difference in his sentencing. Stevens' dissent concluded that the en banc Ninth Circuit's "narrow holding that the District Court abused its discretion in denying respondent an evidentiary hearing should be affirmed."