On Friday, the Ninth Circuit in Brown v. Broomfield affirmed the denial of a habeas corpus petition filed by a prisoner whose 1992 death sentence for a murder 38 years ago was affirmed by California’s Supreme Court (People v. Brown (2003) 31 Cal.4th 518). The Supreme Court also summarily denied two state habeas petitions in 2008. (Here and here.)
Under a standard of review that is highly deferential to state court decisions, the federal appeals court rejected — among other things — various arguments that there was ineffective counsel at the penalty phase of the defendant’s trial and that the defendant was incompetent to stand trial, claims that were the subject of the summarily denied state habeas petitions. The Ninth Circuit concluded “the California Supreme Court could have reasonably determined that Brown failed to make a prima facie claim of ineffective assistance of counsel” and it found the “Supreme Court did not make an unreasonable factual determination that Brown failed to rebut the presumption of competency.”
The Ninth Circuit usually, but not always, refuses to overturn Supreme Court death penalty decisions.
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