In Re Blodgett

1992-01-13

Headline: Delay in a death-penalty appeal: Court denies Washington’s request to force the Ninth Circuit to decide, criticizes the long stay that keeps execution postponed and urges faster handling of the case.

Holding: The Court refused to order the Ninth Circuit to decide the death‑row inmate’s delayed habeas appeal, denying mandamus while criticizing excessive delay and urging the appeals court to expedite resolution.

Real World Impact:

Leaves the execution postponed while the appeals process continues.
Signals appeals courts must resolve capital habeas appeals more promptly after stays.
Allows the State to ask the Supreme Court again for extraordinary relief if delays continue.

Topics: death penalty cases, delays in appeals, federal review of convictions, court speed and administration

Summary

Background

The State of Washington asked the Supreme Court to order the Ninth Circuit to decide an appeal in a death‑penalty case involving Charles Rodman Campbell, who was convicted of multiple murders and sentenced to death. Campbell filed successive federal challenges to his conviction and sentence, and after the Ninth Circuit granted a stay of execution the appeal was argued in June 1989 but no decision followed for years while Campbell pursued other state and federal filings.

Reasoning

The Court examined whether extraordinary relief was warranted to compel the Court of Appeals to act. It expressed serious concern that the more than two‑year stay prejudiced the State and stressed that when a federal court stays an execution it must move promptly to resolve the case. Still, the Supreme Court denied the requested writ of mandamus because Washington had not first sought adequate relief in the Court of Appeals and because the procedural posture called for the Ninth Circuit to address how best to proceed.

Real world impact

The denial leaves Campbell’s execution on hold while the appeals process continues, but the Supreme Court made clear that courts must not tolerate unnecessary delay in capital cases and warned that any further unwarranted postponements will face strict review. The State may seek the same extraordinary relief again if delays persist.

Dissents or concurrances

Justice Stevens, joined by Justice Blackmun, agreed with denying the petition and emphasized that the Ninth Circuit reasonably deferred decision to avoid piecemeal litigation and to consider all of Campbell’s claims together.