Delo v. Blair

Background

A death-row prisoner named Blair filed a third federal habeas petition claiming he is actually innocent and seeking to prevent his scheduled execution. A federal district court denied his claim without holding an evidentiary hearing. The federal Court of Appeals granted a temporary stay so it could consider Blair’s appeal. State corrections officials asked the Supreme Court to vacate that stay.

Reasoning

The central question was whether the Supreme Court should remove the appeals court’s temporary stay. The majority applied the standard that it is particularly egregious to enter a stay on a later habeas petition unless there are substantial grounds for relief. The Court concluded Blair’s claims were indistinguishable from a recent decision the Court had already rejected, found no substantial grounds, and held the appeals court’s stay was an abuse of discretion, so the stay was vacated. Justice Souter would have denied the State’s request.

Real world impact

The decision removes the federal appeals court’s delay and allows the State to proceed unless other courts act. It limits the time available for courts to investigate later-filed innocence claims that the majority views as lacking substantial grounds. Because a dissent argued the district court should have held an evidentiary hearing, the ruling does not finally resolve questions about whether Blair will get a full hearing on his affidavits.

Dissents or concurrances

Justice Blackmun, joined by Justice Stevens, dissented, arguing the appeals court’s stay deserved more deference and that the district court erred by denying Blair an evidentiary hearing despite seven affidavits.