November 08, 2010

Supreme Court Decides Wilson v. Corcoran

On November 8, 2010, the Supreme Court issued a per curiam decision in Wilson v. Corcoran, No. 10-91, holding that a federal court may not issue a writ of habeas corpus without first determining that a state prisoner's confinement violated federal law.

In 1997, Joseph Corcoran was found guilty of four counts of murder by an Indiana jury.  The jury recommended capital punishment based on aggravating circumstances, which are governed by an Indiana statute.  The state trial court agreed with the jury's recommendation and sentenced Corcoran to death.  During the sentencing hearing, however, the trial court referenced the innocence of Corcoran's victims, the heinousness of his offense, and his future dangerousness, none of which are aggravating circumstances under Indiana law.

The Indiana Supreme Court vacated Corcoran's sentence on the basis that the trial court may have weighed the discussed factors as aggravating circumstances.  Upon remand, the trial court wrote that "it only relied upon those proven statutory aggravators" in its sentencing decision.  The Indiana Supreme Court then affirmed the sentence.  Corcoran then applied for a writ of habeas corpus in the Northern District of Indiana, which granted the writ on another ground but was reversed by the Seventh Circuit with instructions to deny the writ.  The Supreme Court granted certiorari, explaining that the Seventh Circuit should have allowed the District Court to consider other grounds for habeas corpus or explained why such consideration was unnecessary.  Upon remand from the Supreme Court, the Seventh Circuit reversed its position and granted habeas relief, holding that the Indiana Supreme Court had made an "unreasonable determination of the facts" when it accepted the trial court's explanation.  The Seventh Circuit directed that the trial court should reconsider its sentencing determination to "prevent non-compliance with Indiana law."

The Supreme Court reversed the Seventh Circuit's decision.  It explained that "it is only noncompliance with federal law that renders a State's criminal judgment susceptible to collateral attack in the federal courts."  Because the alleged error involved contravention of the state's aggravating circumstances statute, habeas corpus relief was unavailable.

The decision was per curiam.

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