Stewart v. LaGrand
Headline: Death-penalty method challenge blocked as Court reverses appeals court, rules inmate waived objection by choosing lethal gas, allowing Arizona to use the inmate’s chosen execution method.
Holding:
- Permits Arizona to proceed with executions by lethal gas when an inmate knowingly chooses that method.
- Makes it harder to challenge execution methods if the prisoner did not raise the issue earlier.
- Rejects ineffective-assistance claims when the defendant waived them and failed to show cause.
Summary
Background
Walter LaGrand and his brother were convicted of serious crimes and sentenced to death in Arizona. Arizona changed its law to give condemned prisoners a choice between lethal gas and lethal injection. Walter repeatedly chose lethal gas and declined the State’s offer to switch to injection. Both brothers later sought federal review arguing that execution by lethal gas was cruel and unusual punishment, and the Ninth Circuit had enjoined Arizona from using gas for some inmates.
Reasoning
The Court addressed whether Walter could press an Eighth Amendment challenge after he had chosen lethal gas. The justices said that by affirmatively selecting gas and rejecting injection, Walter waived any objection to that method. The Court also found his claims procedurally defaulted because he failed to raise the issue earlier and could not show a valid reason for not doing so. The Court rejected Walter’s fallback argument that his lawyer’s ineffectiveness excused the default because he had waived those claims too.
Real world impact
Because the Court reversed the appeals court and vacated its injunction, Arizona may proceed under its rules when prisoners knowingly pick a method of execution. The decision emphasizes that choosing a method can end a later challenge to that method and that failure to raise an issue earlier can block federal review.
Dissents or concurrances
Justice Souter joined part of the opinion but limited his view; Justice Stevens dissented, saying the Court should not decide this important question without full briefing and argument.
Opinions in this case:
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