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: JURIST - The Paper Chase

Supreme Court vacates habeas petition on state law claim

By Ann Riley

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[JURIST] The US Supreme Court [official website; JURIST news archive] on Monday unanimously ruled [opinion, PDF] that lower federal courts may not issue writs of habeas corpus to state prisoners unless their confinement violates federal law. The court overturned a ruling by the US Court of Appeals for the Seventh Circuit [official website] in Wilson v. Corcoran [docket], which granted habeas relief [opinion, PDF] to Joseph Corcoran, convicted of killing four men and sentenced to the death penalty. The court explained that the habeas ruling affirmed by the appeals court was inappropriately based on a deficiency of Indiana state law:

But it is only noncompliance with federal law that renders a State's criminal judgment susceptible to collateral attack in the federal courts. The habeas statute unambiguously provides that a federal court may issue the writ to a state prisoner "only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States." And we have repeatedly held that "federal habeas corpus relief does not lie for errors of state law."

The court vacated and remanded the Seventh Circuit's grant of habeas relief.

In 1997, an Indiana trial court found Corcoran guilty of four counts of murder. The trial judge sentenced him to death, relying on non-statutory aggravating factors. In 2000, the Indiana Supreme Court [official website] vacated the sentence because the trial court may have weighed factors of the innocence of the victims, heinousness of the offense and future dangerousness as aggravating circumstances, and later accepted a revised sentencing order issued in 2002. Corcoran applied for a writ of habeas corpus in the US District Court for the Northern District of Indiana [official website], arguing that the trial court relied on impermissible aggravating factors. In 2007, the district court granted habeas relief on the grounds that the prosecutor violated the Sixth Amendment [text] when offering to take the death penalty off the table in exchange for a waiver of a jury trial. In 2008, the appeals court denied the district court's habeas relief, but later granted the petition on remand from the Supreme Court in 2010, arguing that, in order to comply with Indiana law, the trial court needed to reconsider its sentencing determination.

Full post as published by JURIST - The Paper Chase on November 08, 2010 (boomark / email).