Wilson v. Corcoran
131 S. Ct. 13
| SCOTUS | 2010Background
- Corcoran killed four people, including his brother and sister’s fiancé, leading to four murder convictions and a death sentence after a jury recommended capital punishment.
- Indiana Supreme Court vacated the sentence on remand due to concerns the trial judge relied on nonstatutory aggravators in sentencing.
- On remand, the trial court stated it relied only on statutory aggravators; the Indiana Supreme Court affirmed, finding no lack of clarity and no plausible reason to doubt the reliance on statutory aggravators.
- Corcoran filed a federal habeas petition asserting, among other grounds, that nonstatutory factors were improperly considered on remand, violating the Eighth and Fourteenth Amendments.
- The district court granted relief on a separate Sixth Amendment claim (plea offer to drop death penalty in exchange for waived jury trial) and did not address the sentencing challenge as moot.
- The Seventh Circuit initially remanded to deny the writ but later granted habeas relief on the sentencing claim, concluding nonstatutory factors may have been relied upon, which the Supreme Court vacated and remanded for lack of a federal-law basis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether habeas relief was improper absent a federal violation | Corcoran | Wilson | Writ vacated; no federal-law violation shown |
| Whether nonstatutory aggravators violated federal law in resentencing | Corcoran | Wilson | State-law issues insufficient for federal relief |
| Whether the Seventh Circuit properly addressed the sentencing challenge on remand | Corcoran | Wilson | Seventh Circuit erred by granting relief without a federal-right showing |
| Whether the decision warrants federal review under 28 U.S.C. §2254(a) and (d) | Corcoran | Wilson | Relief not authorized where no federal constitutional violation established |
Key Cases Cited
- Estelle v. McGuire, 502 U.S. 62 (1991) (federal habeas relief not available for state-law errors)
- Lewis v. Jeffers, 497 U.S. 764 (1990) (state-law questions not within federal habeas review)
- Zant v. Stephens, 462 U.S. 862 (1983) (nonstatutory aggravators may be permitted under federal law)
- Wainwright v. Goode, 464 U.S. 78 (1983) (per curiam; discusses federal review limits)
- Corcoran v. Buss, 551 F.3d 703 (2008) (seventh circuit; sentencing claim and waiver issues)
- Corcoran v. Levenhagen, 593 F.3d 547 (2010) (seventh circuit; plain-error review of waiver and state-law compliance)
- Corcoran v. Buss, No official reporter provided (N.D. Ind. 2007) (2007) (district court ruling on Sixth Amendment claim; not cited in report)
- Corcoran v. State, 774 N.E.2d 495, 774 N.E.2d 495 (Ind. 2002) (Indiana Supreme Court remand for resentencing; statutory aggravators control)