Trisha Shetty (Editor)

Stewart v. Martinez Villareal

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Date decided
  
1998

Full case name
  
Terry Stewart, Director, Arizona Department of Correction, et al., Petitioners v. Ramon Martinez-Villareal

Citations
  
523 U.S. 637 (more) 118 S.Ct. 1618; 140 L.Ed.2d 849

Prior history
  
Certiorari to the United States Court of Appeals for the Ninth Circuit

Majority
  
Rehnquist, joined by Stevens, O'Connor, Kennedy, Souter, Ginsburg, Breyer

Dissent
  
Scalia, joined by Thomas

Dissent
  
Thomas, joined by Scalia

Similar
  
Panetti v Quarterman, Ford v Wainwright, Miller‑El v Dretke

Stewart v. Martinez-Villareal, 523 U.S. 637 (1998), was a decision by the United States Supreme Court, which held that 28 U.S.C. § 2244(b) did not apply to a petition that raises only a competency to be executed claim and that respondent did not, therefore, need authorization to file his petition in the District Court.

Factual Background

Martinez-Villareal (Respondent), filed a habeas corpus petition in federal court. Relying on Ford v. Wainwright, which held that the State may not execute an insane person, the Respondent alleged that he was incompetent to be executed.

The State moved to dismiss the Respondents petition as premature and the District Court agreed. Nevertheless, the court granted habeas corpus on other grounds. The District Court's grant was reversed on appeal, but warned that the Respondent's Ford claim could be brought again.

Fearing the passage of the Antiterrorism and Effective Death Penalty Act (AEDPA) might foreclose his Ford claim, Respondent asked the District Court to reopen his Ford claim. The District Court denied the Respondent's request, but assured that the Ford claim would not be foreclosed in future habeas corpus petitions.

Thereafter, the State obtained a warrant for execution of the Respondent. The Arizona Superior Court determined that the Respondent was fit to be executed. Respondent appealed the determination to the State Supreme Court, but the court rejected to review the finding.

Respondent moved to reopen his Ford claim in Federal District Court, however, the court dismissed the claim for lack of jurisdiction according to AEDPA. Respondent appealed the dismissal to Federal Court of Appeals. The Court of Appeals found that the claim was not barred and transferred it back to the District Court.

The Supreme Court granted certiorari.

References

Stewart v. Martinez-Villareal Wikipedia