Today, the United States Supreme Court ruled that Alabama death row inmate Billy Joe Magwood’s challenge to the constitutionality of his death sentence must be heard.
Mr. Magwood initially was convicted of murder and sentenced to death, but a federal court reversed his sentence because his trial lawyer was ineffective. His lawyer failed to adequately present evidence that Mr. Magwood received a Purple Heart for his service in the United States Army in Vietnam, that he suffers from paranoid schizophrenia, that at the time of the crime he was experiencing hallucinations, and that his mental illness helped explain and mitigate the murder.
At his resentencing, the state trial court sentenced Mr. Magwood to death a second time – even though it is not disputed that, at the time of the crime, Mr. Magwood was not eligible for the death penalty under Alabama law. After the appeals of his second sentence were rejected by the state courts, Mr. Magwood again appealed in federal court, challenging his second sentence on the grounds that it was not authorized by Alabama law. The federal district court once again granted relief.
The Eleventh Circuit reversed, holding that Mr. Magwood’s challenge to his second death sentence could not be reviewed because the claim should have been raised in his first appeal.
Today, the United States Supreme Court reversed the Eleventh Circuit and held that Mr. Magwood’s challenge to his second sentence was appropriately raised in his second federal court appeal.
This is the second case in as many weeks in which the Supreme Court has reversed an Eleventh Circuit ruling that denied a death-sentenced person review of claims challenging his death sentence. On June 14, 2010, the Court held that the Eleventh Circuit should have given a Florida death row prisoner a chance to prove that his lawyer’s misconduct caused the filing deadline in his case to be missed.