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United States: Supreme Court Says Federal Courts Should Not Ignore Challenges to a Prisoner's Execution

(Oct. 26, 2009) The U.S. Supreme Court has ruled that in a habeas corpus case challenging a prisoner's execution, a federal appellate court should allow the prisoner's arguments to be considered before ruling that a state may execute him.

An Indiana jury convicted Joseph Corcoran of four counts of murder, and he was sentenced to death. After Corcoran unsuccessfully challenged his sentence in the Indiana courts, he petitioned for habeas corpus relief in federal court, asserting five claims. The district court granted habeas relief on one of the five arguments, namely, that his death sentence violated the Sixth Amendment of the U.S. Constitution, and it ordered the state courts to resentence Corcoran to a penalty other than death. The district court did not address the other four arguments, because the order to resentence Corcoran rendered them moot. The Seventh Circuit reversed the district court's Sixth Amendment ruling, and, without mentioning Corcoran's other four arguments, remanded the case “with instructions to deny the writ,” stating that “Indiana is at liberty to reinstate the death penalty.” Corcoran sought rehearing, arguing that the Seventh Circuit should allow the district court to consider his other four arguments, but the appellate court denied rehearing, again without addressing the other four claims. Corcoran sought review by the U.S. Supreme Court, which was granted.

The Supreme Court held that the Seventh Circuit erred in disposing of Corcoran's four claims without any explanation. The Court said that the Seventh Circuit should have permitted the district court on remand to consider Corcoran's unresolved challenges to his death sentence or should have itself explained why such consideration was unnecessary. (Corcoran v. Levenhagen, No. 08-10495 (Oct. 20, 2009), available at