Schriro v. Landrigan

Schriro v. Landrigan, 550 U.S. 465 (2007), was a United States Supreme Court case decided on May 14, 2007. In a 5–4 decision written by Justice Clarence Thomas, the Court held that the District Court had not abused its discretion when it refused to grant an evidentiary hearing to convicted murderer Jeffrey Timothy Landrigan who had instructed his defense counsel not to put on any mitigation case during the sentencing phase of a capital murder trial. In doing so, the Supreme Court also reversed the prior ruling to the contrary by the en banc United States Court of Appeals for the Ninth Circuit, which had held that Landrigan was entitled to habeas relief on the grounds that he had received ineffective assistance of counsel. The latter court had also held that the District Court's denial of such a hearing to Landrigan amounted to an "unreasonable determination of the facts", which is one of the two circumstances under which the Antiterrorism and Effective Death Penalty Act of 1996 permits the granting of federal habeas relief to state prisoners.

Background

Jeffrey Timothy Landrigan was convicted of second-degree murder in Oklahoma in 1982. In 1986, while in prison for that murder, Landrigan repeatedly stabbed another inmate, for which he was convicted of assault and battery with a deadly weapon. In 1989, he escaped from prison and murdered Chester Dean Dyer during a burglary. For this crime, Landrigan was convicted of theft, second-degree burglary, and felony murder. At his sentencing hearing for this conviction, Landrigan's lawyer attempted to present mitigating evidence, but Landrigan repeatedly interrupted him, and at Landrigan's request, multiple witnesses who had intended to testify on his behalf did not do so.