Corcoran v. Wilson
2011 U.S. App. LEXIS 12704
7th Cir.2011Background
- Corcoran was convicted of four murders in Indiana and sentenced to death; direct appeal reviewed by Indiana Supreme Court.
- Indiana Supreme Court vacated the death sentence for potential improper use of non-statutory aggravating factors; remanded for reimposition with an explanatory order.
- On remand, trial court reimposed death; Indiana Supreme Court affirmed; Corcoran waived post-conviction relief after a competency finding, later changed his mind.
- Corcoran filed a federal habeas petition; district court initially granted relief on a Sixth Amendment claim and ordered resentencing; Indiana appealed and Corcoran cross-appealed.
- Seventh Circuit reversed part of district court’s decision on appeal, and Supreme Court vacated and remanded for further proceedings, citing procedural missteps.
- On remand, Seventh Circuit reinstates previous partial denial and remands to district court to address remaining habeas claims in the first instance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Sixth Amendment claim remains in play | Corcoran contends the writ should stand due to Sixth Amendment violation. | Wilson contends the district court erred in granting relief on the Sixth Amendment issue. | Remanded for consideration of remaining claims; Sixth Amendment relief is not sustained on its merits in this opinion. |
| Whether the Indiana competency finding bars relief | Corcoran argues competency to waive post-conviction remedies was mishandled. | Wilson maintains the competency finding was proper. | Indiana courts' competency determination affirmed; no habeas relief on this ground. |
| Whether state-law error in death-sentencing procedure violated federal due process | Corcoran asserts state-law error affected federal rights. | Wilson argues state-law issue does not establish federal entitlement to relief. | Remanded to address remaining habeas grounds; no clear federal-right violation decided here. |
| Whether the case should have been remanded to district court to decide remaining claims | Corcoran seeks full district-court consideration of unresolved claims. | Wilson advocates district-court adjudication of remaining grounds in the first instance. | Case remanded to the district court to address Corcoran's remaining grounds for habeas relief. |
Key Cases Cited
- Wilson v. Corcoran, 131 S. Ct. 13 (Supreme Court, 2010) (remands for further proceedings on state-law issues and federal-right implications)
- Corcoran v. Levenhagen, 130 S. Ct. 8 (Supreme Court, 2009) (remanded for proper consideration of unresolved habeas issues)
- Corcoran v. Buss, 551 F.3d 703 (7th Cir. 2008) (reversed district court's grant of habeas relief on Sixth Amendment claim; affirmed competence ruling)
- Corcoran v. Buss, 551 F.3d 707 (7th Cir. 2008) (addressed numerous cumulative issues; remand implications on remaining grounds)
- Estelle v. McGuire, 502 U.S. 62 (Supreme Court, 1991) (federal review of state-law errors; due-process concerns)
- United States v. Jackson, 390 U.S. 570 (Supreme Court, 1968) (prohibits considering certain state-law concessions as constitutional rights under federal law)