James v. Ryan

Although Johnson v. Williams grants state courts “the benefit of the doubt” when there is unclear reasoning for its holding, federal courts are not required to disregard a state court’s clear explanation of its own decision to deny the claim based solely on state procedural grounds.

Steven James received a death sentence after being convicted of first-degree murder and kidnapping. In response, James filed three Postconviction Relief (“PCR”) petitions. For his first PCR petition, James argued he received ineffective assistance of counsel (“IAC”) by his trial attorney due to the attorney failing to present mitigating evidence. The court dismissed this claim, holding that it was procedurally barred since James did not raise it on direct appeal. For his second PCR petition, James argued that he received IAC by his trial, appellate, and first PCR counsel. However, the court also dismissed this claim, holding that it was precluded from granting relief since James had already raised IAC by his trial attorney in his first PCR proceeding. For his third PCR petition, James again raised IAC by his trial counsel in addition to other claims. The court again dismissed this claim holding that it was procedurally barred. All three courts denied the claims solely on procedural grounds without discussing the merits of the ineffective counsel. James filed a petition for a writ of habeas corpus, and the Ninth Circuit granted habeas relief from his death sentence. However, the United States Supreme Court vacated the panel’s decision, and the case was remanded for the panel to view James’s petition in light of Johnson v. Williams. To prevail, James needed to convince the panel that his third PCR court failed to “adjudicate that claim ‘on the merits.’” The panel affirmed its prior holding that all three PCR courts denied the claim solely on procedural grounds and never discussed James’s claim regarding ineffective assistance of counsel. Because Williams did not affect the panel’s prior decision, James was still entitled to “habeas relief from his death sentence.”AFFIRMED in part; REVERSED and REMANDED in part.