The Supreme Court held in a 6–3 ruling on May 23 that federal courts reviewing inmate cases may not conduct evidentiary hearings to fully examine their ineffective-counsel claims that should have been raised in state court proceedings.
The Sixth Amendment to the U.S. Constitution guarantees a criminal defendant the right to effective assistance of counsel.
The ruling is a victory for the state of Arizona, but a defeat for the two death-row inmates who claimed they had compelling claims that their lawyers failed to act on in state court. The decision is expected to make it more difficult for prisoners throughout the United States to argue they received ineffective counsel in state court in post-conviction proceedings.
Arizona Attorney General Mark Brnovich, a Republican, praised the high court’s decision.
“The wheels of justice take time to turn, but they should not be stuck for decades,” Brnovich said in a statement that his office provided to The Epoch Times.
“I applaud the Supreme Court’s decision because it will help refocus society on achieving justice for victims, instead of on endless delays that allow convicted killers to dodge accountability for their heinous crimes.”
The respondents, David Martinez Ramirez and Barry Lee Jones, were each convicted of capital crimes in state court in Arizona and sentenced to death.
Court records indicate that on May 25, 1989, Ramirez fatally stabbed his girlfriend, Mary Ann Gortarez, and her 15-year-old daughter, Candie, in their home. Gortarez was stabbed 18 times in the neck with a pair of scissors; Candie, 15 times in the neck with a box cutter. Ramirez later admitted he had sex with the child the night of the murder and four times prior.
On May 1, 1994, Jones sexually assaulted and repeatedly beat his girlfriend’s 4-year-old daughter, Rachel Gray, so savagely that he ruptured her small intestine.
The Arizona Supreme Court affirmed each case on direct review, and each prisoner was denied post-conviction relief in state court. Each also challenged the lawfulness of his detention in federal court, arguing that trial counsel had been ineffective for failing to conduct adequate investigations.
The federal district court held in both cases that the prisoners’ ineffective-assistance claim was procedurally faulty because it was not properly presented in state court. To succeed on such a claim, a prisoner has to demonstrate “cause” to excuse the procedural defect and “actual prejudice,” Thomas wrote in the court opinion, citing previous precedents.
The majority opinion by Thomas was joined by the court’s five other conservatives–Chief Justice John Roberts, and Justices Samuel Alito, Neil Gorsuch, Brett Kavanaugh, and Amy Coney Barrett.
Doing what the convicted men in this appeal wanted would bog down the courts, needlessly delay justice, and reduce legal certainty, Thomas wrote.
“In our dual-sovereign system, federal courts must afford unwavering respect to the centrality ‘of the trial of a criminal case in state court,’” the court’s most senior justice wrote, citing precedent.
“That is the moment at which ‘society’s resources have been concentrated ... in order to decide, within the limits of human fallibility, the question of guilt or innocence of one of its citizens,’” he wrote, again citing caselaw.
“Serial relitigation of final convictions undermines the finality that is essential to both the retributive and deterrent functions of criminal law.
“Such intervention is also an affront to the State and its citizens who returned a verdict of guilt after considering the evidence before them. Federal courts, years later, lack the competence and authority to relitigate a State’s criminal case.
“Permitting federal factfinding would encourage yet more federal litigation of defaulted claims.”
Sotomayor’s dissenting opinion, which described the majority opinion as “perverse” and “illogical,” was joined by Justices Stephen Breyer and Elena Kagan.
The Supreme Court has recognized the guarantee of effective counsel at trial “as ‘a bedrock principle’ that constitutes the very ‘foundation for our adversary system’ of criminal justice,” Sotomayor wrote, citing precedent.
“Today, however, the Court hamstrings the federal courts’ authority to safeguard that right. The Court’s decision will leave many people who were convicted in violation of the Sixth Amendment to face incarceration or even execution without any meaningful chance to vindicate their right to counsel.”
Robert Loeb, the counsel of record for the prisoners, said the decision “amounts to an assault on basic fairness in the criminal justice system.”
The ruling “is tragic for Barry Jones, who remains in prison notwithstanding evidence which the district court determined undercut the murder charge against him—evidence showing that the conviction was based on assertions that were scientifically untrue,” Loeb said in a statement forwarded by his office to The Epoch Times.
“It is also tragic for David Ramirez, who faces the death penalty with no court to hear the powerful mitigating evidence (of his intellectual disability and the abuse he suffered as a child) that would have prevented the imposition of the death penalty.
“It means that a federal court can have evidence that someone, like Barry Jones, did not commit the crime supporting the death sentence, but that the court then is helpless to offer any relief.”
