Styers v Ryan

It has never been held by the Arizona Supreme Court that a conditional writ of habeas corpus that has been issued necessarily means that a sentence or conviction resulted from a constitutional error.

James Styers was one of two people who shot the victim three times in the head. Subsequently, Styers was charged and convicted of first degree murder, conspiracy to commit first degree murder, child abuse, and kidnapping. The Arizona Supreme Court reviewed the post-traumatic stress disorder (PTSD) evidence as it had mitigating qualities, but concluded that Styers did not produce any evidence to establish a causal connection between the PTSD he claimed to have and the actual crime. The district court ruled against Styers. On appeal, the Ninth Circuit reviewed whether the district court justly denied Styers writ for unconditional habeas corpus motion. The panel reasoned that since the U.S. Supreme court has “never held that the issuance of a conditional writ of habeas corpus necessarily renders non-final a conviction or sentence that was predicated on constitutional error” and the death sentence would not be vacated, the Arizona Supreme Court’s ruling that the sentence was final, as previously done in 2011 with Styers case, was not contrary to Federal law. Further, the Arizona Supreme Court was allowed to give the PTSD factor little weight because there is no “method for balancing mitigating and aggravating factors in a capital sentencing proceeding." AFFIRMED.