Jones v. Chappell
2014 U.S. Dist. LEXIS 97254
C.D. Cal.2014Background
- Ernest Dewayne Jones was sentenced to death in California in April 1995 and, after lengthy state and federal review, challenged California’s death-penalty administration as unconstitutional due to systemic delay; the federal habeas petition was pending in 2014.
- Since California’s modern death-penalty system began in 1978, over 900 people have been sentenced to death but only 13 executed; the majority remain on Death Row for decades, with many dying of natural causes before execution.
- Extensive studies (including the California Commission on the Fair Administration of Justice) documented systemic delays at every stage: long waits for appointment of appellate and habeas counsel, underfunding, slow briefing and calendaring, and prolonged state and federal habeas adjudication.
- Average time from sentence to execution in California often exceeds 25 years; many inmates wait 3–5 years for appellate counsel and 8–10 years for habeas counsel appointment; state habeas decisions and federal exhaustion stays add further multi-year delays.
- Jones argued the systemic, state-created delays have produced an arbitrary system in which only a trivial, randomly selected few are executed and for those executed delay defeats retributive and deterrent purposes; the court found returning Jones to state court for exhaustion would compound the dysfunction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether systemic, inordinate delay in California's post-conviction process renders death sentences unconstitutional under the Eighth Amendment | Jones: statewide dysfunction causes arbitrary selection of a tiny fraction for execution and destroys deterrence/retribution, so continued death sentence is unconstitutional | State: delay is largely attributable to necessary safeguards and petitioners' delays; courts have rejected delay-as-cruel-and-unusual claims | Court: Held systemic delay produced arbitrariness and defeat of penological purposes; vacated Jones's death sentence |
| Whether the delay is attributable to the State or to petitioners | Jones: most delay stems from state-created structural problems (underfunding, procedural rules, backlog) | State: many delays are caused by inmates' tactics and exhaustive review requirements | Court: Found record shows majority of delay is state-caused and unnecessary; Commission recommendations show feasible shorter timelines |
| Whether exhaustion of state remedies is required before federal habeas relief for this systemic claim | Jones: exhaustion would be futile and only prolong the unconstitutional process; statutory exception for ineffective state processes applies | State: argues procedural default/exhaustion doctrines bar federal review | Court: Found special circumstances render state process ineffective; exhaustion not required here |
| Whether the rule Jones seeks to apply is new for Teague purposes | Jones: claim applies longstanding Eighth Amendment principle against arbitrary imposition of death | State: (implicitly) that announcing the rule would be new and barred | Court: Held the principle is not new—rooted in Furman and long-standing Eighth Amendment doctrine; Teague does not bar relief |
Key Cases Cited
- Furman v. Georgia, 408 U.S. 238 (establishing that arbitrary imposition of the death penalty violates the Eighth Amendment)
- Gregg v. Georgia, 428 U.S. 153 (upholding guided capital sentencing and endorsing retribution and deterrence as penological purposes)
- Woodson v. North Carolina, 428 U.S. 280 (recognizing the qualitative difference of death and heightened need for reliability)
- Harmelin v. Michigan, 501 U.S. 957 (noting deterrent effect depends on certainty and promptness of punishment)
- Kennedy v. Louisiana, 554 U.S. 407 (reaffirming that capital punishment must serve deterrence or retribution to be constitutional)