Charles Hedlund v. Charles Ryan
2014 U.S. App. LEXIS 7692
9th Cir.2014Background
- Hedlund was convicted of first-degree murder for McClain and sentenced to death; he and McKinney were tried with dual juries.
- A leg brace was imposed for security during Hedlund’s trial; the court minimized visibility; he challenged it but court affirmed security rationale.
- The court empaneled dual juries over objections; after trial, Hedlund challenged but Arizona Supreme Court upheld the dual-jury approach.
- Hedlund argued juror bias concerns arose when a juror disclosed a distant relation to a victim; Remmer/Smith framework applied and found no actual bias.
- Hedlund pursued plea negotiations; a second plea offer was rejected after defense sought recusal; district PCR rejected claims of ineffective counsel for the plea strategy.
- Mitigating evidence (childhood abuse, alcohol use) was considered; Arizona Supreme Court reweighed factors; AEDPA review applied to Lockett/Eddings standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Leg restraint during trial | Hedlund contends leg brace violated fair-trial rights. | State justified security interest; restraint necessary. | Not contrary to clearly established federal law; justified by essential state interest. |
| Use of dual juries | Dual juries risked prejudice; violated due process. | Dual juries permitted as discretionary trial technique. | No clearly established federal-law rule prohibiting dual juries; not reversible. |
| Juror bias | Juror’s relatedness to a victim risked bias; Remmer standard met. | Hedlund failed to prove actual bias; hearing sufficed. | Trial court’s bias inquiry complied with Remmer/Smith; no actual bias shown. |
| Plea-process ineffective assistance | Counsel erred by letting second plea offer expire; prejudicial. | Counsel acted under reasonable tactical decisions; no prejudice. | State PCR reasonable under Strickland; no deficient performance established. |
| Mitigating evidence under Lockett/Eddings | Mitigating childhood abuse and alcohol use must be given independent weight. | Arizona courts properly weighed mitigating evidence; nexus not required for admissibility. | Mitigating evidence was considered and not constitutionally excluded; no Eddings error. |
Key Cases Cited
- Holbrook v. Flynn, 475 U.S. 560 (U.S. 1986) (shackling requires an essential state interest; minimal restraints allowed)
- Illinois v. Allen, 397 U.S. 337 (U.S. 1970) (restrains permissible for safety when necessary)
- Remmer v. United States, 347 U.S. 227 (U.S. 1954) (due-process bias inquiries require a hearing with interested parties)
- Smith v. Phillips, 455 U.S. 209 (U.S. 1982) (due-process bias hearing sufficient to determine actual bias)
- Zafiro v. United States, 506 U.S. 534 (U.S. 1993) (severance not required; joint trial permissible absent substantial prejudice)
- Tennard v. Dretke, 542 U.S. 274 (U.S. 2004) (no nexus requirement for mitigating evidence; weight may vary)
- Smith v. Texas, 543 U.S. 37 (U.S. 2004) (rejects nexus test for mitigating evidence; weight allowed)
- Lockett v. Ohio, 438 U.S. 586 (U.S. 1978) (sentencer must consider all relevant mitigating evidence)
- Eddings v. Oklahoma, 455 U.S. 104 (U.S. 1982) (cannot preclude mitigation evidence; weight in sentencing may vary)
- Penry v. Lynaugh, 492 U.S. 302 (U.S. 1989) (mitigation must be considered; not limited to statutory factors)
- Towery v. Ryan, 673 F.3d 933 (9th Cir. 2012) (limits on nexus test; weight discretion retained)
- Schad v. Ryan, 671 F.3d 708 (9th Cir. 2012) (discusses Schad standard for applying nexus test)