James v. Ryan

Where the defendant was sentenced to death, capital defense counsel’s assistance was ineffective during sentencing where counsel failed to introduce mitigating evidence of the defendant’s extensive childhood exposure to violence, drug abuse, poverty, and sexually predatory adults, and of his history of drug abuse, suicide attempts, and mental illness.

In 1984, Steven James was convicted and sentenced to death for murder and kidnapping. In 2000, after three failed petitions for post-conviction relief (“PCR”), the district court denied, without a hearing, James’ petition for writ of habeas corpus. James appealed on three grounds: the state’s failure to disclose a plea agreement made with a codefendant; the state’s failure to correct a codefendant’s testimony denying the agreement; and ineffective assistance by trial counsel at sentencing. The Ninth Circuit affirmed the two guilt-phase claims based on Brady, Giglio, and Napue, finding that the nondisclosure and false testimony about a plea agreement were not material, since the codefendant’s testimony could have been corroborated. The Court reviewed the penalty-phase claim for ineffective assistance of counsel, de novo, noting that the PCR court’s brief statement that there were “no colorable claims” was not an adjudication on the merits, but rested solely on procedural grounds. Thus, deference under the Antiterrorism and Effective Death Penalty Act did not apply. The Court found “counsel’s penalty-phase performance prejudicially deficient” where counsel failed to investigate and present mitigating evidence of James’s troubled childhood, mental illness, and history of chronic drug abuse, which prevented the sentencing judge from learning of James’ troubled history, which is relevant in assessing moral culpability. Further, the heinousness of the crime does not preclude prejudice, and mitigating factors are a “constitutionally indispensable part of the process of inflicting the penalty of death.” AFFIRMED in part; REVERSED and REMANDED.