In re Davis

2009-08-17
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Headline: Court sends a death-row inmate’s new-evidence claim to a federal trial court for an evidentiary hearing to decide if new proof shows he is truly innocent.

Holding: The Court transferred Troy Davis’s petition to a federal district court and ordered that court to hold an evidentiary hearing to determine whether new evidence clearly establishes his innocence.

Real World Impact:
  • Requires a federal court hearing on newly discovered innocence evidence.
  • Could prevent execution if a district court finds the new evidence credible.
  • Keeps open whether federal limits on review bar relief for proven innocence.
Topics: death penalty, new evidence of innocence, witness recantation, federal court hearing

Summary

Background

Troy Davis, convicted in the killing of a police officer and facing execution, says new evidence shows he is innocent. Several of the State’s key trial witnesses have recanted, and some later statements point to the prosecution’s main witness as the shooter. Lower courts had not held a full hearing to test the reliability of those new affidavits.

Reasoning

The central question was whether a federal court should take testimony and decide if evidence that was not available at trial clearly proves innocence. The Court transferred the case to a federal district court and directed it to receive testimony and make findings about whether the new evidence clearly establishes innocence. Justice Stevens emphasized that the risk of executing an innocent person justifies a hearing and noted unresolved questions about whether a federal statute that limits habeas review applies to this kind of original petition or to clear claims of actual innocence.

Real world impact

The transfer sends the matter to a lower federal court to test the new evidence in open proceedings. If the district court finds the new proof credible, that could prevent a planned execution. The decision is procedural and not a final ruling on guilt or innocence; the lower court must now hold the evidentiary hearing and decide the outcome.

Dissents or concurrances

Justice Stevens wrote a separate opinion joined by Justices Ginsburg and Breyer criticizing Justice Scalia’s view that no relief should follow even strong innocence evidence; Justice Sotomayor did not take part in the consideration or decision.

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