Roper v. Weaver

2007-05-21

Headline: Death-row review canceled as Court dismisses its own review and leaves the appeals court ruling intact, avoiding unequal treatment of three similarly situated inmates after a district-court procedural error.

Holding: The Court canceled its review and dismissed the case without deciding whether the stricter AEDPA federal-review rule applies, choosing discretion to avoid treating three similarly situated death-row inmates differently due to a district-court error.

Real World Impact:

Cancels Supreme Court review and leaves the appeals court decision standing for now.
Prevents immediate clarification on how AEDPA applies to similar death-penalty cases.
Avoids treating three similarly situated inmates differently because of a district-court error.

Topics: death penalty, prosecutor closing arguments, appeals and habeas review, procedural rules

Summary

Background

A man sentenced to death challenged his sentence in federal court after state courts denied postconviction relief. He filed a federal habeas petition before a major 1996 law took effect, but a district court later dismissed that petition after he sought this Court’s review. He then refiled, and an appeals court evaluated his claims under the stricter post-1996 review rule and set aside his death sentence because of the prosecutor’s closing argument.

Reasoning

The Supreme Court had agreed to decide whether the appeals court had misapplied the stricter federal-review rule. The Justices found that the district court was wrong to dismiss the original petition and that a recent decision made clear the dismissal was erroneous. Rather than decide the technical question about how the 1996 law applies here, the Court used its discretion to avoid treating three nearly identical defendants differently because of the earlier procedural mistake.

Real world impact

Because the Court dismissed its review, it did not resolve whether the stricter federal-review rule applies to this petition or whether the prosecutor’s statements required reversal. The appeals court’s handling of the case remains on the books for now. The decision was aimed at preventing one defendant from getting a different result only because of a lower-court error.

Dissents or concurrances

The Chief Justice agreed with the outcome but not all the reasons. One Justice dissented, arguing the Court should have decided the main legal question and criticizing the dismissal for leaving the appeals court’s ruling in place.