Sowden v. United States
Headline: Court denies review of a prisoner's claim that a notorious jailhouse informant lied, leaving the Ninth Circuit’s finding that the state court unreasonably credited the witness and preserving habeas relief for now.
Holding: The Court denied review and left the Ninth Circuit’s finding that the state court unreasonably credited the jailhouse informant in place, supporting the convicted man’s habeas claim.
- Leaves the convicted man’s habeas relief intact based on informant unreliability.
- Affirms federal courts can overturn unreasonable state factual findings in habeas cases.
- Highlights risks when convictions rely on jailhouse informant testimony.
Summary
Background
Bobby Joe Maxwell is a man convicted in the 1984 Skid Row killings who claimed a jailhouse informant, Sidney Storch, falsely testified that Maxwell confessed. The California courts found no credible evidence that Storch lied, but the Ninth Circuit reviewed extensive new and historical evidence suggesting Storch repeatedly fabricated confessions and other facts for personal gain.
Reasoning
The legal question was whether the state court’s factual finding was unreasonable under the federal habeas law that directs deference to state courts but allows relief for unreasonable factual determinations. The Ninth Circuit concluded the state court’s finding was unreasonable after listing many instances showing Storch’s unreliability. Justice Sotomayor agreed with denying Supreme Court review, emphasizing that deference does not require abandoning meaningful federal review of unreasonable factual findings.
Real world impact
The Court’s denial of review leaves the Ninth Circuit’s judgment in place, which favors Maxwell’s claim based on the alleged false testimony. This is not a full Supreme Court decision on the merits; rather, it preserves the appellate ruling that the state court’s factual finding was unreasonable under federal habeas law. The case highlights risks when convictions rest on testimony from jailhouse informants.
Dissents or concurrances
Justice Scalia, joined by Justice Alito, dissented from the denial, arguing the Ninth Circuit improperly second-guessed the state court, stressed strict deference under federal habeas law, and warned retrial could be impossible due to lost evidence and witnesses.
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