Another murderer getting all the attention
I cannot find much (if anything) of broad jurisprudential significance in the Landrigan decision from the Supreme Court today (basics here). Though others may see something important in this ruling, Landrigan strikes me as another example of the Court simply deciding to be in the business of error correction in a capital case.
For this reason, I cannot help but yet again express my frustration about how much energy and judicial resources federal courts devote to state capital cases and to state defendants who have committed the most awful of crimes. Here is how courts have described the defendant at issue in today’s ruling: “before he was 30 years of age, Landrigan had murdered one man, repeatedly stabbed another one, escaped from prison, and within two months murdered still another man.”
Not surprisingly, and seemingly justifiably under applicable state law, this behavior landed Landrigan on Arizona’s death row. But, after state court review, Landrigan’s federal habeas action prompts hordes of federal judges to give his case copious attention. Seeking some finality, the district court denied Landrigan an evidentiary hearing trying to extend his attack on the state court outcome; a Ninth Circuit panel unanimously affirmed this decision. But, apparently with nothing better to do, the full Ninth Circuit decided to review Landrigan’s case en banc and ordered the district court to conduct an evidentiary hearing. Thereafter, rather than leave well enough alone, the Supreme Court decided this case was so important that it merited cert, full argument and lengthy opinions to determine that, in the end, the district court acted within its discretion when denying an evidentiary hearing.
Meanwhile, as dozens of federal judges and lawyers obsess over the whether double-murderer Landrigan should get an evidentiary hearing to extend his attack on the state court outcome, thousands of non-violent federal offenders languish in prison without being able to get even a trio of circuit judges to explore thoroughly their non-capital sentencing arguments.