Styers v. Ryan

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Petitioner was convicted of first degree murder and other charges and sentenced to death. This court subsequently found that the Arizona Supreme Court had erred in not considering certain mitigation evidence, because it found such evidence was not connected to petitioner’s actions at the time of the murder. The court reversed and remanded to the district court to issue a conditional writ ordering petitioner's release from his death sentence unless the State were to initiate proceedings either to correct the constitutional error or to vacate the death sentence and impose a lesser sentence. The district court so ordered and the state court affirmed the death sentence. Petitioner then moved the district court for an unconditional writ of habeas corpus, arguing that the Arizona Supreme Court was powerless to correct the constitutional error, because the law had changed since Styers I. Petitioner made a Ring v. Arizona claim before the state court, arguing that the conditional writ of habeas corpus required that petitioner be re-sentenced and that a jury must find the aggravating factors rendering him eligible for the death penalty. The state court denied the claim on the ground that petitioner's sentence was final. The U.S. Supreme Court has never held that the issuance of a conditional writ of habeas corpus necessarily renders non-final a conviction or sentence that was predicated on constitutional error, and the conditional writ of habeas corpus in this case did not vacate petitioner’s death sentence. Therefore, the court concluded that the state court's determination that petitioner's sentence remained final at the time of the second independent review was not contrary to federal law as determined by the Supreme Court of the United States. Finally, the state court considered the mitigating evidence and decided to give it little weight. Neither Tennard v. Dretke, nor Eddings v. Oklahoma, requires more. Accordingly, the court affirmed the judgment. View "Styers v. Ryan" on Justia Law