(CN) - Supreme Court pressure did not stop the 9th Circuit on Friday from ordering resentencing in a case where a gay man was murdered for allegedly flirting with the wrong guy.
Steven James was on death row for the 1981 kidnapping and murder of Juan Maya in Arizona.
James and accomplices, Lawrence Libberton and Martin Norton, allegedly beat Maya savagely, drove him into the desert, and shot him and hit him with rocks before dumping his body in an old mine shaft. Libberton and Norton were also convicted of murder in separate proceedings in Arizona state court.
James filed three unsuccessful state petitions for post-conviction relief based on his trial attorney's alleged failure during the penalty phase of the trial to present potentially mitigating evidence about his social history, mental health and drug abuse.
Eventually a three-judge panel of the 9th Circuit found that the state court had failed to address the merits of his ineffective assistance of counsel claim.
The U.S. Supreme Court vacated
that decision in March, however, citing its holding in Johnson v. Williams
In the earlier case, the justices denied habeas relief to a woman named Tara Sheneva Williams who was convicted of murder after the trial judge dismissed a rogue juror. They found that the Antiterrorism and Effective Death Penalty Act (AEDPA) of 1996 "sharply limits the circumstances in which a federal court may issue a writ of habeas corpus to a state prisoner whose claim was 'adjudicated on the merits in state court proceedings.'"
Ordered to reconsider James' case in that light, the federal appeals court in San Francisco again ordered habeas relief on Friday.
Nothing in Johnson v. Williams
upsets the contention that a thorough investigation by James' attorney could have revealed "powerful mitigating evidence" against a death sentence, according to the ruling.
The state court in James' case failed to consider the merits of the ineffective assistance of council claim in his third petition for post-conviction relief, the 9th Circuit concluded.
instructs us to give state courts the benefit of the doubt when the basis for their holdings is unclear," Judge William Fletcher wrote for the appellate panel. "It does not require us to ignore a state court's explicit explanation of its own decision."
Fletcher added that "nothing in Williams
affects the substance of our decision that James's counsel provided unconstitutionally ineffective assistance at the penalty phase of his trial."
The circuit sent the case back to the U.S. District Court in Arizona for resentencing. James' death sentence will automatically convert to life in prison if the state fails to resentence him within "a reasonable amount of time."