Schriro v. Landrigan

Schriro v. Landrigan
Supreme Court of the United States
Argued January 9, 2007 Decided May 14, 2007
Full case name	Dora B. Schriro, Director, Arizona Department of Corrections, Petitioner v. Jeffrey Timothy Landrigan, aka Billy Patrick Wayne Hill
Docket no.	05-1575
Citations	550 U.S. 465 (more) 127 S.Ct. 1933, 167 L.Ed.2d 836
Argument	Oral argument
Opinion announcement	Opinion announcement
Case history
Prior	441 F. 3d 638 (CA9 2006)
Subsequent	501 F. 3d 1147 (CA9 2007)
Holding
The District Court did not abuse its discretion in refusing to grant Landrigan an evidentiary hearing. United States Court of Appeals for the Ninth Circuit reversed and remanded.
Court membership
Chief Justice John Roberts Associate Justices John P. Stevens · Antonin Scalia Anthony Kennedy · David Souter Clarence Thomas · Ruth Bader Ginsburg Stephen Breyer · Samuel Alito
Case opinions
Majority	Thomas, joined by Roberts, Scalia, Kennedy, Alito
Dissent	Stevens, joined by Souter, Ginsburg, Breyer
Laws applied
Antiterrorism and Effective Death Penalty Act of 1996

Schriro v. Landrigan, 550 U.S. 465 (2007), 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.

External links

• Text of Schriro v. Landrigan is available from: Cornell  Google Scholar  Justia  Library of Congress  Oyez (oral argument audio)