Steven James v Charles L. Ryan
2012 U.S. App. LEXIS 4100
| 9th Cir. | 2012Background
- Death-sentenced Steven James appeals district court denial of habeas corpus petition arising from 1981 murder of Juan Maya by James, Libberton, Norton in Arizona.
- Norton, age 14 at the time, testified under a juvenile plea; later statements and a purported oral plea agreement are central to Brady/Giglio/Napue claims.
- Trial focused on James’s guilt phase (murder/kidnapping) and penalty phase (death). Jury found James guilty of first-degree murder and kidnapping; death sentence imposed after judge-found aggravators.
- James claims Brady/Giglio/Napue nondisclosure/false testimony and ineffective penalty-phase counsel for failing to present mitigating evidence of his background, mental illness, and drug abuse.
- State PCR proceedings concluded mainly on procedural bars; federal court reviews de novo for claims not adjudicated on merits; court ultimately remanded for writ of habeas relief on penalty-phase claim.
- Court grants writ and remands for re-sentencing, holding Pillinger’s penalty-phase performance deficient and prejudicial; new mitigation evidence could yield life sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady/Giglio/Napue materiality | James | Ryan | Brady/Giglio/Napue claims denied; not material. |
| Penalty-phase ineffective assistance | James | State | Procedural default; de novo review; defendant entitled to relief; remanded. |
| Was claim adjudicated on merits via 3rd PCR? | James | State | State relied on procedural bar; court treated as not merits-based; de novo review allowed. |
| New evidence standard under Pinholster | James | State | Pinholster not controlling where claim not adjudicated on merits; new evidence considered. |
| Impact of mitigation evidence on death sentence | James | State | Powerful mitigation could change outcome; court remands for writ to grant relief. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (duty to disclose exculpatory evidence)
- Giglio v. United States, 405 U.S. 150 (1972) (impeachment value of withheld deal evidence)
- Napue v. Illinois, 360 U.S. 264 (1959) (false testimony must be material)
- Ring v. Arizona, 536 U.S. 584 (2002) (jury determinations required for aggravating factors in capital cases)
- Schriro v. Summerlin, 542 U.S. 348 (2004) (nonretroactivity of Ring in some contexts; AEDPA interplay)
- Porter v. McCollum, 130 S. Ct. 447 (2009) (detailed mitigation evidence required in capital cases)
- Rompilla v. Beardon, 545 U.S. 374 (2005) (duties of defense counsel to investigate mental health and background)
- Mayfield v. Woodford, 270 F.3d 1128 (2001) (mitigation and drug-use context in capital sentencing)