Twenty-two years ago, the Supreme Court unanimously affirmed Ricardo Sanders’ death sentence. (People v. Sanders (1995) 11 Cal.4th 475.) A few months later, the court summarily denied his state habeas corpus petition. Yesterday, the Ninth Circuit affirmed a district court’s denial of federal habeas relief, in Sanders v. Cullen.
Sometimes the Ninth Circuit validates Supreme Court rulings (e.g., here and here), sometimes it doesn’t (e.g., here and here).