Runningeagle v. Ryan

A district court does not err in denying a habeas corpus claim when the petitioner fails to show that withheld evidence is material and favorable; mere speculation is not enough.

Sean Runningeagle appealed the district court’s denial of his petition for a writ of habeas corpus. In 1987, Mr. and Mrs. Herbert Williams were found murdered in their home. Runningeagle was convicted of two counts of first degree murder and several lesser charges, and sentenced to death. Corey Tilden was also convicted for the deaths, but sentenced to life in prison. Runningeagle made several claims under the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”). First, he argued that the prosecution withheld evidence of the testimony of Tilden’s cellmate. Tilden’s cellmate allegedly told prosecutors that Tilden acted alone. Under AEDPA, a habeas petition will not be granted on any claim unless it resulted in a decision that was based on a “contrary or unreasonable application of federal law.” The Court held that the lower court’s denial of the petition was not an unreasonable application of federal law in light of the cellmate’s alleged testimony, because withheld evidence must be material and favorable, and “mere speculation” of what a cellmate told prosecution is not sufficient. Next, Runningeagle made two AEDPA claims based on ineffective counsel. The Court upheld the lower court’s decision on both claims, holding that the defense counsel was not ineffective in failing to join Tilden’s motion to sever trial, because their defenses were not “mutually exclusive or antagonistic.” Second, the Court held that the failure to petition for separate sentencing hearings does not render counsel ineffective when no evidence indicates that the court would have balanced the factors differently had the defendants been given separate proceedings. Last, the Court upheld the lower court’s denial because Runningeagle’s due process rights were not violated when the prosecution made an improper comment. AFFIRMED.