Capital Case Roundup — Death Penalty Court Decisions the Weeks of January 4 and 112021

Seal_Of_The_United_States_Supreme_Court

NEWS (1/​13 – 16/​21) — Federal: The fed­er­al gov­ern­ment has exe­cut­ed Lisa Montgomery, Corey Johnson, and Dustin Higgs. The U.S. Supreme Court and the fed­er­al cir­cuit courts of appeals col­lec­tive­ly vacat­ed 17 sep­a­rate pre­lim­i­nary injunc­tions or stays of exe­cu­tion on the way to per­mit­ting 13 exe­cu­tions in a six-month peri­od. The U.S. Supreme Court grant­ed every appli­ca­tion by fed­er­al pros­e­cu­tors to vacate injunc­tions or stays of exe­cu­tion and denied every appli­ca­tion by the death row pris­on­ers to halt or delay their executions.


NEWS (1/​15/​21) — Texas: The Texas Court of Criminal Appeals grant­ed a stay of exe­cu­tion to Blaine Milam, who was sched­uled to be put to death on January 21. The court returned Milam’s case to the tri­al court for a sec­ond time to con­sid­er his claim that he is inel­i­gi­ble for the death penal­ty because of intellectual disability.


NEWS (1/​13/​21) — Alabama: The U.S. District Court for the Middle District of Alabama has over­turned the death sen­tence imposed on Richard Flowers. The court ruled that Flowers had been pro­vid­ed defi­cient rep­re­sen­ta­tion at tri­al, in the penal­ty phase, and in the sen­tenc­ing hear­ing before the tri­al judge, but found that he had suf­fered prej­u­dice only with respect to his sentence.

The court wrote: Mr. Flowers was rep­re­sent­ed by a cas­cade of unpre­pared tri­al attor­neys, with his sec­ond-chair coun­sel becom­ing the de fac­to lead coun­sel a mere six­teen days after his appoint­ment and thir­ty min­utes pri­or to open­ing argu­ment. Defense coun­sel failed to con­duct any mean­ing­ful inves­ti­ga­tion – – and no inves­ti­ga­tion of mit­i­gat­ing evi­dence – – and failed to file rou­tine pre­tri­al motions until in the shad­ow of a jury.” Flowers sen­tenc­ing judge had imposed the death penal­ty fol­low­ing a non-unan­i­mous 10 – 2 jury rec­om­men­da­tion of death.


NEWS (1/​8/​21) — Arizona: The U.S. Court of Appeals for the Ninth Circuit has affirmed the Arizona dis­trict court’s denial of habeas relief for Murray Hooper, reject­ing on tech­ni­cal grounds his claims that the pros­e­cu­tion had uncon­sti­tu­tion­al­ly with­held excul­pa­to­ry evi­dence and relied on lat­er over­turned con­vic­tions to sen­tence him to death.

Hooper argued that pros­e­cu­tors had with­held or delayed dis­clo­sure of mul­ti­ple pieces of excul­pa­to­ry evi­dence in vio­la­tion of the U.S. Supreme Court’s 1963 rul­ing Brady v. Maryland. The court denied the claim on the grounds that no clear­ly estab­lished fed­er­al law exist­ed on whether Bradys pro­hi­bi­tion against with­hold­ing excul­pa­to­ry evi­dence also applied to evi­dence that was with­held up until the tri­al itself. It also ruled that it could not over­turn his death sen­tence based on the prosecution’s use of pri­or con­vic­tions that were sub­se­quent­ly over­turned, say­ing that the con­sti­tu­tion­al pro­hi­bi­tion against the use of such con­vic­tions had not been clear­ly estab­lished at the time Arizona’s courts decid­ed his direct appeal.

Finally, the court ruled that Hooper had not been denied the effec­tive assis­tance of penal­ty-phase coun­sel, despite the fact that his tri­al coun­sel had not pre­sent­ed any mit­i­gat­ing evi­dence in his sentencing hearing. 


NEWS (1/​5/​21) — Tennessee: The Tennessee Supreme Court grant­ed a stay of exe­cu­tion to Oscar Smith, who had been sched­uled to be put to death on February 4. The court stayed Smith’s exe­cu­tion pend­ing fur­ther order of this Court,” cit­ing mul­ti­ple issues caused by the con­tin­u­ing COVID-19 pandemic.”