Winfield v. Steele
2014 U.S. App. LEXIS 11805
| 8th Cir. | 2014Background
- Winfield was convicted in Missouri state court of multiple counts of first-degree murder, assault, and armed criminal action and sentenced to death.
- In 2014 the Missouri Supreme Court scheduled Winfield’s execution for June 18, 2014.
- Winfield filed suit to stay the execution on grounds that state actors obstructed his clemency efforts by pressuring a staff member to withdraw support.
- The district court held an evidentiary hearing and issued a June 12, 2014 stay, and preliminarily enjoined officials from pressuring staff from supporting clemency.
- Staff member Cole initially agreed to provide a clemency letter but withdrew after being investigated for “over-familiarity”; Cole later signed a declaration in support before rescinding it.
- The Department of Corrections later provided Cole’s signed declaration to the governor, and Winfield remained able to pursue clemency, with no evidence of broader suppression.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether state actions affecting clemency support violated due process | Winfield argues MDOC intimidation violated due process by interfering with clemency support. | Steele argues minimal due process safeguards apply; actions do not render clemency process arbitrarily unfair. | Vacate stay; minimal due process satisfied; no due process violation found |
| Whether the state’s conduct approached arbitrariness or coercion warranting relief | Winfield contends interference resembled coercion undermining clemency access. | State asserts safeguards were minimal and not arbitrarily denying access to clemency. | Conduct not equivalent to coin-flip arbitrariness; no substantial due process violation |
| Whether the district court abused its discretion in issuing the stay | Winfield asserts stay appropriate due to potential due process violation. | State contends district court properly applied Young v. Hayes and did not abuse discretion. | No abuse of discretion; vacate stay |
Key Cases Cited
- Ohio Adult Parole Authority v. Woodard, 523 U.S. 272 (U.S. 1998) (minimal due-process safeguards may apply to clemency)
- Hill v. McDonough, 547 U.S. 573 (U.S. 2006) (due process in clemency contexts; standard for relief)
- Young v. Hayes, 218 F.3d 850 (8th Cir.2000) (state cannot obstruct clemency process; requires minimal due process)
- Noel v. Norris, 336 F.3d 648 (8th Cir.2003) (due process when state interferes with clemency access)
- Duvall v. Keating, 162 F.3d 1058 (10th Cir.1998) (minimal due process for clemency procedures)
- Roll v. Carnahan, 225 F.3d 1016 (8th Cir.2000) (states must not frustrate clemency petition access)
- Baze v. Thompson, 302 S.W.3d 57 (Ky.2010) (state may not deny clemency information; minimal due process)
- Faulder v. Texas Bd. of Pardons & Paroles, 178 F.3d 343 (5th Cir.1999) (minimal due process; extreme situations guide intervention)