James v. Schriro
2011 U.S. App. LEXIS 20652
9th Cir.2011Background
- Steven James was death-sentenced for the 1981 Juan Maya murder in Arizona; Norton testified against James under a juvenile disposition after cooperation and a plea, while Libberton also faced conviction and relief in later proceedings.
- James challenged suppression of Norton’s oral plea agreement and false Napue/Giglio-Napue-related testimony, and claimed trial counsel was ineffective at the penalty phase for failing to present mitigating evidence.
- The court rejected James's guilt-phase Brady/Giglio/Napue challenges, holding the state’s non-disclosure or misstatement not material in light of corroborating statements and independent evidence of guilt.
- The court vacated and remanded to grant habeas relief on the penalty-phase ineffective assistance claim, finding deficient performance in investigating James’s troubled upbringing, mental illness, and lifelong drug abuse, which prejudiced the sentencing outcome.
- Procedural posture: the district court denied relief; the court held the Brady/Giglio/Napue claims were handled on the merits, but allowed de novo review for the ineffective-assistance claim due to not being adjudicated on the merits in state court.
- The result is a partial affirmance of guilt-phase claims and a remand with instruction to grant the writ as to the death sentence, with resentence by the state or conversion to life if not resentenced.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady/Giglio/Napue materiality | James claims non-disclosure and false testimony were material. | State contends disclosure was non-material given corroboration. | No material impact; Brady/Giglio/Napue claims fail. |
| Procedural default on IAC claim | Arizona defaulted the IAC claim via its rules. | State argues adequate procedural bar. | Default inadequate; review de novo. |
| Penalty-phase ineffective assistance—deficient performance | Counsel failed to investigate and present comprehensive mitigation. | State argues trial record supported decision; no prejudice shown. | Deficient performance; prejudice shown; remand for writ. |
| Prejudice from mitigation failure | Mitigation evidence would have changed the balance against heinous/depraved finding. | Mitigation evidence was insufficient to alter outcome. | Sufficient probability of different result; writ granted. |
| Evidentiary hearing in federal court | District court erred in denying; remand without hearing. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (exclusion of favorable evidence violates due process)
- Giglio v. United States, 405 U.S. 150 (1972) (impeachment evidence materiality depends on disclosure timing and corroboration)
- Napue v. Illinois, 360 U.S. 264 (1959) (false testimony material if it could affect the verdict)
- Wiggins v. Smith, 539 U.S. 510 (2003) (mitigation investigation required; deficient performance prejudices)
- Penry v. Lynaugh, 492 U.S. 302 (1989) (mitigation evidence relevant to moral culpability)
- Ring v. Arizona, 536 U.S. 584 (2002) (jury must determine aggravating factors for death sentence)
- Schriro v. Summerlin, 542 U.S. 348 (2004) (nonretroactivity of Ring and standards for pretrial competency/mitigation)
- Beardslee v. Woodford, 358 F.3d 560 (2004) (remanding for legal questions without fact disputes in habeas)
- Porter v. McCollum, 130 S. Ct. 447 (2010) (holistic mitigation analysis and prejudice)