James Styers v. Charles Ryan, 811 F.3d 292

Background

James Lynn Styers was convicted of first-degree murder (and related counts) for the 1989 killing of a child and sentenced to death; Arizona Supreme Court affirmed in 1993.
Styers presented mitigating evidence including PTSD from military service; Arizona Supreme Court originally discounted PTSD because it found no causal link to the crime.
Ninth Circuit (Styers II) held Arizona’s review violated Eddings/Smith by excluding mitigation not causally tied to the crime and issued a conditional writ requiring the State to correct the error or vacate the death sentence.
Arizona Supreme Court invoked its A.R.S. § 13-755 independent-review power, reconsidered the mitigation evidence (again giving PTSD little weight), and reaffirmed the death sentence (Styers III).
Styers argued on federal habeas that Ring required jury resentencing (because his sentence was non-final after the conditional writ) and that the Arizona court failed to cure the Eddings error; the district court denied relief and the Ninth Circuit affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ring requires jury resentencing after state court’s attempted correction	Styers: conditional writ rendered sentence non-final; Ring entitles him to jury findings of aggravators	State: Arizona Supreme Court’s independent review under §13-755 cured error; sentence remained final so Ring does not apply	Court: Arizona’s determination that sentence remained final was not contrary to federal law; Ring did not require resentencing
Whether Arizona Supreme Court’s reweighing cured the Eddings error	Styers: the state process was constitutionally inadequate and treated mitigation as de minimis	State: the court reconsidered mitigation and independently weighed it against aggravators under §13-755	Court: independent review that considered PTSD and gave it little weight satisfied Eddings/Tennard; no unreasonable application of federal law
Whether the state court’s interpretation of §13-755 is reviewable here	Styers: §13-755 independent review should be limited to direct review so post-conviction cure was invalid	State: §13-755 permits independent review of death sentences and was properly applied	Court: defers to Arizona Supreme Court on state-law statutory interpretation; federal habeas cannot relitigate it
Whether factual finding that PTSD did not affect conduct was unreasonable under §2254(d)(2)	Styers: evidence showed PTSD influenced him; factual finding was unreasonable	State: record supported Arizona’s factual determination and its weighing	Court: declined to expand certificate of appealability; did not find unreasonable factual determination

Key Cases Cited

Eddings v. Oklahoma, 455 U.S. 104 (1972) (sentencer must consider all relevant mitigating evidence)
Smith v. Texas, 453 U.S. 37 (1981) (prohibits exclusion of mitigating evidence not causally related to crime)
Ring v. Arizona, 536 U.S. 584 (2002) (jury must find any fact that increases maximum punishment for capital defendants)
Teague v. Lane, 489 U.S. 288 (1989) (new procedural rules generally do not apply retroactively to cases on collateral review)
Griffith v. Kentucky, 479 U.S. 314 (1987) (new rules apply to cases not yet final on direct review)
Clemons v. Mississippi, 494 U.S. 738 (1990) (appellate reweighing may cure certain sentencer errors)
Schriro v. Summerlin, 542 U.S. 348 (2004) (Ring announces procedural rule applicable only to cases on direct review)
Tennard v. Dretke, 542 U.S. 274 (2004) (mitigating evidence need not have causal nexus to crime to be considered)
Kansas v. Marsh, 548 U.S. 163 (2006) (no single constitutionally required method for balancing aggravation and mitigation)
Johnson v. Fankell, 520 U.S. 911 (1997) (federal courts defer to state courts on state-law matters)
Coleman v. Thompson, 501 U.S. 722 (1991) (adequate and independent state grounds bar federal review)
Harvest v. Castro, 531 F.3d 737 (9th Cir. 2008) (standard of review for §2254 denials)