In Carter v. Davis, the Ninth Circuit affirmed two different district court denials of habeas corpus relief to a condemned inmate sentenced to death in different California counties for multiple murders in 1984. The Supreme Court had affirmed the death sentences (People v. Carter (2005) 36 Cal.4th 1114; People v. Carter (2005) 36 Cal.4th 1215) and denied a number of state court habeas corpus petitions, most recently in 2010 (here, here, here, here, and here).
The federal appellate court said it was reviewing the Supreme Court’s decisions under “standards [that, for prisoners,] are ‘intentionally “difficult to meet.”’” Because of that highly deferential standard, the Ninth Circuit usually, but not always, refuses to overturn California death sentences.
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