Miles v. Ryan
713 F.3d 477
9th Cir.2012Background
- Miles challenged only his capital sentence under 28 U.S.C. § 2254; he did not challenge his felony murder conviction.
- Trial court sentenced Miles to death after finding three aggravators and rejecting most mitigators.
- Sattler, his sentencing counsel, relied on portraying Miles as a normal person with depression, rather than focusing on addiction.
- New social-history information emerged during state post-conviction relief showing Miles’s mother’s prostitution and Miles’s early life in a drug-using environment.
- Arizona court PCR denial held that defense strategy and lack of additional mitigation did not show deficient performance or prejudice.
- Federal district court allowed new mitigation evidence; court applied AEDPA review and Martinez v. Ryan considerations to decide on relief despite new material.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Effectiveness of sentencing counsel’s focus on addiction | Miles argues failure to focus on addiction was deficient | Sattler’s strategy aimed to portray Miles as normal; addiction not weighty | No relief; strategic choice reasonable under Strickland/Pinholster |
| Qualifications of the expert and its prejudice | Excluded Levy testimony prejudiced Miles | Testimony would add little; judge had other basis | No prejudice under Strickland; AEDPA deferential review applied |
| Investigation of Miles’s social history | Counsel failed to perform thorough mitigation investigation | Investigation aligned with strategy; additional history marginal | No relief under AEDPA; later evidence insufficient to undermine outcome |
| Effect of Martinez v. Ryan on post-conviction representation | Martinez may permit de novo review for substantial underlying claims | Martinez does not aid where post-conviction counsel not ineffective | Martinez does not compel relief here; underlying claims not shown substantial |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong standard for ineffective assistance of counsel)
- Porter v. McCollum, 558 U.S. 30 (U.S. 2009) (mitigation investigation duties regardless of defendant cooperation)
- Rompilla v. Beard, 545 U.S. 374 (U.S. 2005) (deficient mitigation investigation despite limited cooperation)
- Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (duty to investigate background evidence; substantial preparation required)
- Pinholster v. Ayers, 131 S. Ct. 1388 (S. Ct. 2011) (limits consideration of new evidence under AEDPA review; Brett Pinholster standard)
- Knowles v. Mirzayance, 556 U.S. 111 (U.S. 2009) (double deference in AEDPA review; reasonable application of Strickland)
- Martinez v. Ryan, 132 S. Ct. 1309 (S. Ct. 2012) (exception to exhaustion for ineffective assistance of trial counsel claims)