Madden v. Texas
Headline: Justice Scalia narrows deadline extensions for death-row inmates' Supreme Court petitions, granting short 30-day delays in three Texas cases but refusing an extension for a man with a scheduled execution.
Holding: In these four Texas capital cases, the Justice granted 30-day extensions in three cases but denied the extension for the inmate with a scheduled execution, ruling last-minute withdrawals or delays do not automatically justify extensions.
- Limits extensions for death-row inmates' Supreme Court petitions to short, case-by-case delays.
- Refuses extension when an execution date falls soon after the filing deadline.
- Rejects automatic leniency for last-minute attorney withdrawals or routine counsel assistance requests.
Summary
Background
A lawyer affiliated with the Texas Resource Center asked for 60-day extensions to file Supreme Court review petitions on behalf of four people convicted of capital murder and sentenced to death in Texas. State courts affirmed the convictions and denied rehearing on November 28, 1990 (one opinion issued earlier on September 12). The ninety-day filing deadline in each case ran to February 26, 1991. One prisoner had an execution date set for February 28, 1991; the others did not. The extension requests were shipped by overnight courier on February 15 and were received on February 16, the last day allowed under the Court's ten-day advance application rule.
Reasoning
The Justice considered the Court's rules that allow a Justice to extend the ninety-day filing period up to sixty days for good cause and that require extension requests at least ten days before the deadline. He found that routine requests for assistance, or an attorney's withdrawal, do not automatically supply good cause. He explained that the withdrawal in one case (because counsel became a Member of Congress) could have been anticipated, and that the death of a volunteer lawyer's father did not justify an extension when other lawyers at the Resource Center could have done the work. Balancing those factors, he denied the extension for the man with the near execution date and granted only a thirty-day extension in the other three cases.
Real world impact
This ruling enforces tight deadlines for death-row petitioners seeking Supreme Court review in the Fifth Circuit and signals that last-minute staffing problems will not by themselves produce long extensions. Lawyers and clients must act earlier to secure counsel and file on time. Because this decision resolves only procedural extension requests and not the inmates' convictions, the underlying cases may still proceed on other legal grounds.
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