Rhoades v. Henry
2011 U.S. App. LEXIS 2578
| 9th Cir. | 2011Background
- Rhoades was convicted in Idaho state court of first-degree murder, kidnapping, and robbery in the 1987 Baldwin killing and was sentenced to death for the murder and kidnapping, with a life term for robbery.
- Baldwin, an employee at the Red Mini Barn, was shot multiple times; a gun found near the defendant’s Ford LTD and ballistic evidence linked to the same weapon used in other related murders.
- A Nevada search and subsequent arrest in Wells, NV, led to Miranda warnings; Rhoades admitted, in various exchanges, that he committed the crimes.
- Forensic and other physical evidence—footprints, hair, a watch like Baldwin’s, and shell casings—connected Rhoades to the scene and weapon.
- Buchholz confessed in a drunken tirade; defense sought to introduce Christian’s testimony about Buchholz’s statements, but the court excluded it as untrustworthy hearsay under Idaho Rule 804(b)(3).
- Rhoades pursued federal habeas corpus review under AEDPA; the district court denied relief, and the Ninth Circuit affirmed, with portions remanded/clarified by later amendments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Buchholz confession and related testimony | Rhoades argues due process requires admission of Buchholz’s confession via Christian’s testimony. | State argues lack of trustworthiness and lack of corroboration make it inadmissible. | No due process violation; exclusion upheld; testimony would be unreliable and cumulative. |
| Brady violations regarding undisclosed Buchholz/Wallace materials | Non-disclosures could have affected trial outcome. | Disclosures were cumulative or not material. | No Brady violation; disclosures, viewed collectively, would not have altered outcome. |
| Admissibility of the second 'I did it' Miranda statement | Statement admitted despite possible invocation of right to silence. | Statement was after a valid Miranda waiver and not the product of coercive interrogation. | Admissible; no due process violation; Mosley standard not violated. |
| Constitutionality of jury instructions 16, 17, and 27 | Instructions lowered standard of proof or the presumption of innocence. | Instructions, read as a whole, correctly stated burden and preserved due process. | No Winship/Cage error; instructions were constitutional as a whole. |
| Ineffective assistance of counsel for sentencing mitigation investigation | Counsel failed to adequately investigate mitigation evidence. | New mitigation evidence would not have changed the outcome given strong aggravators. | No prejudice; Strickland standard not met; sentencing affirmed. |
Key Cases Cited
- Coker v. Georgia, 433 U.S. 584 (Supreme Court 1977) (death penalty disproportionate for certain nonlethal offenses)
- Eberhart v. Georgia, 433 U.S. 917 (Supreme Court 1977) (death penalty in kidnapping cases where death not intended)
- Enmund v. Florida, 458 U.S. 782 (Supreme Court 1982) (death penalty for accomplice with no intent to kill)
- Kennedy v. Louisiana, 554 U.S. 407 (Supreme Court 2008) (death penalty for rape of a child unconstitutional where no death intended)
- Michigan v. Mosley, 423 U.S. 96 (Supreme Court 1975) (limits on continuing interrogation after invoking rights)
- Victor v. Nebraska, 511 U.S. 1 (Supreme Court 1994) (reasonable doubt standard and jury understanding)
- Cage v. Louisiana, 498 U.S. 39 (Supreme Court 1990) (danger of letting jurors use non-relevant factors to convict)
- Strickland v. Washington, 466 U.S. 668 (Supreme Court 1984) (ineffective assistance standard: deficient performance and prejudice)
- Kyles v. Whitley, 514 U.S. 419 (Supreme Court 1995) (consider evidence collectively for prejudice under Brady)
- Rompilla v. Beard, 545 U.S. 374 (Supreme Court 2005) (mitigation evidence and capital-sentencing standards)
- Wiggins v. Smith, 539 U.S. 510 (Supreme Court 2003) (extensive mitigation evidence and capital sentencing)
- Williams v. Taylor, 529 U.S. 362 (Supreme Court 2000) (mitigation evidence and reasonable probability of different outcome)
- Porter v. McCollum, 130 S. Ct. 447 (Supreme Court 2009) (totality of mitigation evidence vs. aggravation in capital sentencing)
- Leavitt v. Arave, 383 F.3d 809 (9th Cir. 2004) (instruction identical to challenged one; constitutionality analysis)
- Reynolds v. United States, 238 F.2d 460 (9th Cir. 1956) (disapproval of problematic jury instruction)
- Booth v. Maryland, 482 U.S. 496 (Supreme Court 1987) (victim impact statements and their admissibility at sentencing; later narrowed)