Lonchar v. Thomas

116 S. Ct. 1293 (U.S. 1996); No. 95-5015 (U.S. Apr. 1, 1996) ; Clearinghouse Number: 51111

Description

Court of Appeals Erred on Equitable Grounds in Dismissing Petitioner's First Federal Habeas Petition Filed Eight Years After Conviction

Abstract

The Supreme Court has held that the Eleventh Circuit erred on equitable principles in dismissing petitioner's first federal habeas petition. Petitioner was sentenced to death in 1987, and his conviction was affirmed on appeal. Throughout these proceedings, petitioner said that he wanted to die and refused to cooperate with his lawyer or to attend his trial. In 1990, petitioner's sister filed a "next friend" habeas petition in state court, which was dismissed. In 1990, petitioner filed his own state habeas petition, which he withdrew. In 1995, petitioner's brother filed another "next friend" state habeas petition, which petitioner opposed and which was also dismissed. On his scheduled execution day, petitioner filed another state habeas petition containing 22 claims which petitioner told the court he was litigating only to delay his execution in the hope that if the state changed its execution method to lethal injection he could donate his organs. The state court denied habeas relief, and petitioner filed his first federal habeas petition setting forth the same 22 claims. The district court rejected the state's argument that the petition should be dismissed because of petitioner's "inequitable conduct" in waiting almost six years to file a federal petition and granted a stay of execution. The court of appeals vacated the stay and held that equitable principles independent of Habeas Corpus Rule 9 applied. Petitioner appealed. The Supreme Court held that when faced with a request for a stay in a first federal habeas case, if the district court cannot dismiss the petition on the merits before the scheduled execution, it is obligated to address the merits and must issue a stay to prevent the case from becoming moot. The Court found that the court of appeals erred in dismissing petitioner's first federal petition for special ad hoc "equitable" reasons not encompassed within the relevant statutes, the Federal Habeas Corpus Rules, or prior precedents.

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Docket Date
1970-01-01 06:00:00+00:00

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