Steven James v. Charles L. Ryan
733 F.3d 911
9th Cir.2013Background
- James was Arizona inmate sentenced to death for 1981 murder/kidnapping of Juan Maya; murder deemed especially heinous; prior state postconviction petitions were procedurally barred or denied.
- In James II we held trial counsel’s penalty-phase IAC was established by lack of investigation into social history, mental health, and drug use, yielding a reasonable probability of reversal.
- The State’s postconviction arguments centered on whether the third PCR court adjudicated the IAC merits or conduct was procedurally barred; James II remanded for Williams guidance.
- The Supreme Court remanded to consider Johnson v. Williams; Williams held a state court’s decision can adjudicate a federal claim on the merits even when it fails to discuss it, affecting Richter presumption.
- On remand, the court concluded Williams does not require treating the third PCR court’s decision as a merits adjudication; James remains entitled to habeas relief from the death sentence, while guilt-phase Brady/Giglio and Napue claims remain denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the third PCR court adjudicated IAC on the merits | James contends merits adjudication occurred; AEDPA applies | State argues procedural bar and no merits adjudication | No merits adjudication; procedural bar, not merits ruling. |
| Whether Williams alters AEDPA review or Richter presumption | James relies on Williams to treat as merits adjudication | State argues Williams overrides prior rule | Williams does not alter the presumption; no merits adjudication found. |
| Whether Williams affects James II’s outcome on penalty-phase IAC | Williams requires de novo review under Williams framework | Williams does not change the outcome | No change; penalty-phase IAC relief remains. |
| Whether guilt-phase Brady/Giglio and Napue claims remain denied under AEDPA | James seeks habeas relief on these claims as well | State maintains the original denials were correct | Remains denied under AEDPA; relief awarded only for death sentence. |
Key Cases Cited
- James v. Ryan (James II), 679 F.3d 780 (9th Cir. 2012) (affirms IAC reversal and discusses deference framework under AEDPA; clarifies procedural-bar posture)
- James v. Schriro (James I), 659 F.3d 855 (9th Cir. 2011) (de novo review for penalty-phase IAC; Hodges-based analysis under AEDPA)
- Harrington v. Richter, 131 S. Ct. 770 (Supreme Court 2011) (establishes AEDPA review framework and Richter presumption for merits determinations when silent on merits)
- Williams v. Johnson, 133 S. Ct. 1088 (Supreme Court 2013) (holds state court may adjudicate federal claim on the merits despite not stating it; informs Richter/Williams interplay)
- Johnson v. Williams, 133 S. Ct. 1088 (Supreme Court 2013) (explicitly addresses Williams decision and its impact on adjudication-on-merits determinations)