Crawford v. Mississippi

Background

Charles Ray Crawford is a man convicted in Mississippi of murdering Kristy Ray after a 1998 trial. His court-appointed lawyers repeatedly told jurors Crawford had committed the acts and pursued an insanity defense, even though Crawford repeatedly insisted he wanted to be found not guilty and instructed counsel to challenge the State’s evidence. He continued to press his claim in state and federal postconviction proceedings and, after the Supreme Court decided McCoy v. Louisiana (which said lawyers may not override a defendant’s clear choice to maintain innocence), Crawford asked the Mississippi Supreme Court to apply that rule to his old case.

Reasoning

The central question the dissent says the Court should have taken is whether McCoy applies to cases like Crawford’s where the conviction became final before McCoy — in other words, whether that rule is retroactive and can be raised on collateral review. The dissent explains that McCoy flowed from long-standing rules that a defendant controls certain basic choices, so McCoy may simply apply existing law rather than announce a new rule. If McCoy applies, the dissent argues Crawford’s lawyers plainly violated his right to direct his defense and that such an error requires automatic reversal, which would spare him execution.

Real world impact

Because the Court denied the stay and declined review, the state-court decision stands and Crawford’s execution remains scheduled. The larger question about whether defendants can use McCoy to reopen old cases is left unresolved, producing a split in lower courts that affects other defendants and state courts grappling with similar claims.

Dissents or concurrances

Justice Sotomayor, joined by Justices Kagan and Jackson, dissented from the denial, urging a stay and review because a man’s life is at stake and because lower courts are divided on the retroactivity question.