Schriro v. Smith

Background

In 1982, Robert Douglas Smith was convicted in Arizona of first-degree murder, kidnaping, and sexual assault, and sentenced to death. He unsuccessfully pursued state appeals and postconviction relief. Smith later filed a federal habeas corpus petition, which the District Court denied in 1996. At trial he had presented evidence showing low intelligence during sentencing, but he did not previously argue that he was mentally retarded or ineligible for execution. After rounds of appeals and petitions, and after this Court decided Atkins, Smith asserted mental retardation and sought relief.

Reasoning

The main question was who should decide whether a condemned person is mentally retarded and therefore ineligible for execution under Atkins. The Ninth Circuit told Arizona courts to hold a jury trial to resolve Smith’s claim and ordered federal habeas proceedings suspended. The Supreme Court found that the Ninth Circuit exceeded its limited habeas authority. Atkins had said States should develop their own procedures, and Arizona had not yet applied its chosen procedures. The Court therefore vacated the Ninth Circuit’s judgment and remanded for further proceedings consistent with this opinion.

Real world impact

The ruling leaves it to Arizona and other States to follow their own procedures when deciding mental retardation claims about execution eligibility. It prevents an appellate court from pre-emptively imposing a jury trial requirement on state courts. The decision sends Smith’s case back for further steps under Arizona’s processes and makes clear the question can be addressed by state courts first. Smith’s motion to proceed without paying fees was also granted.