Tuesday, October 20, 2009

Supreme Court Reverses Denial Of Habeas Petition In Death Penalty Case

The Supreme Court issued an opinion and reversed the Seventh Circuit in JOSEPH E. CORCORAN v. MARK LEVENHAGEN, SUPERINTENDENT, INDIANA STATE PRISON (08-10495). That opinion can be found here.

An Indiana jury convicted Joseph Corcoran of fourcounts of murder. Corcoran was sentenced to death. After Corcoran’s challenges to his sentence in the Indiana courts failed, he sought federal habeas relief. Corcoran argued inhis federal habeas petition that: (1) the Indiana trial court committed various errors at the sentencing phase; (2) hissentence violated the Sixth Amendment; (3) Indiana’s capital sentencing statute was unconstitutional; (4) the prosecution committed misconduct at sentencing; and (5)he should not be executed because he suffers from a men-tal illness. See Corcoran v. Buss, 483 F. Supp. 2d 709, 719, 726 (ND Ind. 2007).
The Seventh Circuit reversed the District Court’s Sixth Amendment ruling. Corcoran v. Buss, 551 F. 3d 703, 712, 714 (2008). Then, without mentioning Corcoran’s other sentencing claims, the Seventh Circuit remanded “with instructions to deny the writ,” stating that “Indiana is atliberty to reinstate the death penalty.” Id., at 714.
We now grant certiorari and hold that the Seventh Circuit erred in disposing of Corcoran’s other claims with-out explanation of any sort. The Seventh Circuit should have permitted the District Court to consider Corcoran’sunresolved challenges to his death sentence on remand, or should have itself explained why such consideration was unnecessary.


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