Wednesday, March 26, 2003
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U.S. Supreme Court, in 6-3 Ruling, Overturns Order Granting New Trial to California Death Row Inmate
Justices Reject Ninth Circuit’s View of Timeliness Requirement for Habeas Corpus
By a MetNews Staff Writer
The Antiterrorism and Effective Death Penalty Act’s restrictions on habeas corpus petitions apply to any petition filed on or after the act’s effective date, even if a related paper such as a motion for stay of execution or for appointment of counsel was filed earlier, the U.S. Supreme Court ruled yesterday.
The justices, in a 6-3 decision, overturned a Ninth U.S. Circuit Court of Appeals ruling granting a new trial to Robert F. Garceau and sent the case back to the appeals court for reconsideration under the tightened standards of AEDPA.
The 1996 law, among other things, precludes the grant of habeas corpus relief from a state conviction unless the highest state court’s interpretation of federal law is “contrary to” or “an unreasonable application of” relevant U.S. Supreme Court authority.
Cases Affected
The Attorney General’s Office estimated that about 45 death penalty cases in the state are affected by yesterday’s ruling. It had asked the high court to review the merits of the Ninth Circuit ruling as well, but the justices limited their grant of review to the issue of when a petition becomes “pending” for AEDPA purposes.
Garceau, from Kern County, was sentenced to death in 1987 for killing his girlfriend and her son, allegedly so they would not inform the police of his drug dealing.
Maureen Bautista and her 14-year-old son Telesforo were stabbed to death in September 1984. Six months later, Susan Rambo—the widow of a drug dealer who had been recently murdered himself—led police to the corpses which were buried in her backyard.
Garceau was convicted of murdering Greg Rambo, who had allegedly helped him bury the Bautistas, and sentenced to 33 years to life imprisonment. Prosecutors then introduced evidence of the Rambo murder at Garceau’s trial for the Bautista murders.
Immunity Granted
They also presented testimony from Susan Rambo—under grant of immunity—that she helped dig the hole in her backyard, where a dresser containing the Bautistas’ bodies was buried. Several other prosecution witnesses were implicated in covering up the Bautista murders or the Rambo murder, or in the drug business.
Jurors were told by Kern Superior Court Judge Lewis King that they could consider the evidence of the Rambo murder for any purpose, “including but not limited to...[Garceau’s] character or any trait of his character” or “conduct on a specific occasion.”
Garceau argued on appeal that the instruction violated due process by inviting jurors to treat the Rambo killing as proof of a propensity to commit murder. The California Supreme Court agreed the instruction was wrong, but said it was harmless beyond a reasonable doubt.
U.S. District Judge Oliver Wanger of the Eastern District of California agreed. But as a threshold matter, he ruled—consistent with a 1998 Ninth Circuit decision—that AEDPA did not apply because Garceau had filed a motion for stay and a motion for counsel prior to April 24, 1996, when the act took effect
The Ninth Circuit also held AEDPA inapplicable, citing its earlier decision, and—in a 2 to 1 ruling—held that the instruction was prejudicial since jurors might otherwise not have been willing to convict on the testimony of drug dealers.
‘Pending’ Clarified
But the Supreme Court, which ruled in 1997 that AEDPA applies to cases “pending” on its effective date, clarified that holding yesterday by saying that a habeas corpus case is not pending until the petition is filed. Five circuits had earlier reached that conclusion, with the Ninth Circuit the only one to reach a contrary conclusion.
Justice Clarence Thomas, writing for the majority, said the Ninth Circuit ruling was inconsistent with the intent behind the statute.
“Congress enacted the AEDPA to reduce delays in the execution of state and federal criminal sentences, particularly in capital cases,” Thomas wrote.
Justice David Souter, joined by Justices Ruth Bader Ginsburg and Stephen Breyer, dissented.
Souter reasoned that AEDPA must be read in conjunction with the other laws governing habeas corpus, and that it makes sense to hold that the version to be applied in a given case is the one in effect when the habeas court first takes account of...standards for habeas relief.”
Since the district judge addressed the merits of Garceau’s claims in granting the stay, the case should be deemed as having been pending when he did so, Souter argued.
The case is Woodford v. Garceau, 01-1862.
Copyright 2003, Metropolitan News Company