Loggins v. Thomas
2011 U.S. App. LEXIS 18572
| 11th Cir. | 2011Background
- Kenneth Loggins was convicted of murder in 1995 and sentenced to death for a capital offense involving kidnapping.
- He was 17 at the time of the crime, leading Alabama courts to vacate the death sentence under Roper v. Simmons and resentence him to life without parole (LWOP).
- Loggins challenged the LWOP sentence as unconstitutional for a juvenile, seeking relief under 28 U.S.C. § 2254.
- State procedures included Rule 32 petitions, a remand for resentencing, and multiple state-court proceedings culminating in a Court of Criminal Appeals decision that Loggins challenged.
- Loggins sought habeas relief in federal court, arguing his Roper-based claims should render his LWOP unconstitutional and that he should have had a sentencing hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Loggins’ claims are procedurally barred and adjudicated on the merits for AEDPA review. | Loggins argues the state court did not adjudicate his Roper-based claims on the merits. | The State contends the state court adjudicated the claims on the merits or, alternatively, that AEDPA applies regardless. | AEDPA deference applies; Loggins’ claims were adjudicated on the merits or are preserved for review under AEDPA. |
| Whether a life-without-parole sentence for a juvenile murderer violates the Eighth Amendment. | Loggins contends Roper and Graham establish juveniles cannot be sentenced to LWOP for homicide. | The State argues Roper and Graham do not clearly proscribe LWOP for juvenile murders; Graham concerns nonhomicide offenses. | Loggins’ LWOP for juvenile homicide is not clearly established as unconstitutional under current Supreme Court holdings. |
| Whether Loggins was improperly denied a sentencing hearing and mitigating evidence at resentencing. | Loggins alleges he should have had a full sentencing hearing with mitigating evidence. | Given mandatory LWOP under Alabama law after vacating the death sentence, no full hearing was required. | Mandatory LWOP following Roper does not require a new full sentencing hearing. |
| Whether the state court decisions were adjudicated on the merits for § 2254(d) review under Harrington/Childers. | Logs contends state court proceedings were barred by procedural grounds and not adjudicated on the merits. | AEDPA deference applies because the state court decisions addressed the claims on the merits. | The state court decisions were adjudications on the merits for § 2254(d) purposes; deference applies. |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (U.S. Supreme Court, 2005) (held it unconstitutional to execute anyone under eighteen at the time of the crime)
- Graham v. Florida, 560 U.S. 48 (U.S. Supreme Court, 2010) (limited LWOP to non-homicide juvenile offenses; did not extend to juvenile murderers)
- Harrington v. Richter, 131 S. Ct. 770 (U.S. Supreme Court, 2011) ( AEDPA § 2254(d) deference applies to merits determinations even without a state-court opinion)
- Wright v. Secretary for the Department of Corrections, 278 F.3d 1245 (11th Cir. 2002) (defined adjudication on the merits as any state court decision denying the claim on the merits)
- Childers v. Floyd, 642 F.3d 953 (11th Cir. 2011) (en banc; broad definition of 'adjudication on the merits' under AEDPA)
- Harmelin v. Michigan, 501 U.S. 957 (U.S. Supreme Court, 1991) (upheld mandatory LWOP for non-capital offenses; supports constitutionality of mandatory LWOP)
- Arrington v. State, 716 So.2d 237 (Ala. Crim. App. 1997) (cannot raise issues on appeal not raised in Rule 32 petition)