Wilson v. Knowles
631 F.3d 1295
9th Cir.2011Background
- Wilson pleaded no contest in 1993 to gross vehicular manslaughter while DUI and to proximately causing bodily injury; single accident with Horvat; Horvat gave Wilson keys and asked him to drive, they picked up a hitchhiker Haessly; Wilson and Horvat were drunk, car wrecked, Haessly killed; Wilson served one year in addiction treatment residence.
- In 2000, Wilson was convicted by a jury of DUI with a prior felony and the trial judge counted his 1993 convictions as the first two strikes under California Penal Code § 667(b)-(i).
- The judge sentenced Wilson to 25 years to life based on treating the 1993 convictions as two strikes and the 2000 conviction as a third strike.
- The prosecutor introduced 1993 documents at the 2000 sentencing to establish that the 1993 conviction for causing injury counted as a strike; the judge made explicit findings that the prior conviction allegation was true.
- The California Court of Appeal affirmed the sentence; Justice Rushing dissented, arguing Apprendi was violated; the California Supreme Court denied review on the merits.
- Wilson sought federal habeas relief; the district court denied, holding no clearly established right to jury trial on the legal significance of a prior conviction; the Ninth Circuit reversed and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Apprendi error occurred in reliance on the prior-conviction exception | Wilson | Knowles | Yes; error in relying on the prior-conviction exception to enhance sentence |
| Whether the error was harmless or reversible | Wilson | Knowles | Harmless error not established; reversal warranted |
| Whether AEDPA deference foreclosed relief given unclear Supreme Court precedent | Wilson | Knowles | AEDPA deference does not bar relief; reversal remanded |
| Whether state court decisions were contrary to or an unreasonable application of clearly established law | Wilson | Knowles | Unreasonable application; reversal and remand for further proceedings |
Key Cases Cited
- Apprendi v. New Jersey, 530 U.S. 466 (2000) (any fact increasing sentence beyond maximum must be proved to a jury aside from the prior conviction)
- Kessee v. Mendoza-Powers, 574 F.3d 675 (9th Cir. 2009) (discusses the boundaries of the prior-conviction exception)
- DeWeaver v. Runnels, 556 F.3d 995 (9th Cir. 2009) (limits on extending clearly established principles to new contexts)
- United States v. Brown, 417 F.3d 1077 (9th Cir. 2005) (per curiam on sentencing fact-finding)
- Harrington v. Richter, 131 S. Ct. 770 (2011) (standard for reviewing state-court decisions under AEDPA)
- Premo v. Moore, 131 S. Ct. 733 (2011) (AEDPA deference in habeas corpus contexts)
- Lockyer v. Andrade, 538 U.S. 63 (2003) (recognizes limits of Apprendi on prior-conviction exception)
- Shepard v. United States, 544 U.S. 13 (2005) (discussion of sentencing-related facts and prior-conviction principles)