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Blair v. Armontrout
Citations: 604 F. Supp. 723; 1985 U.S. Dist. LEXIS 21771Docket: 85-0155-CV-W-5
Court: District Court, W.D. Missouri; March 14, 1985; Federal District Court
Walter J. Blair filed a federal habeas corpus petition under 28 U.S.C. § 2254 after being convicted of capital murder in Missouri, with his execution scheduled for March 20, 1985. The United States District Court for the Western District of Missouri, led by Chief Judge Scott O. Wright, granted Blair's motion for a stay of execution, citing his legal entitlement to such a stay pending habeas corpus review. Blair's conviction was affirmed on direct appeal, and his subsequent motion for post-conviction relief under Missouri Rule 27.26 was denied. The Missouri Supreme Court denied his application for transfer, and a hearing set the execution date without granting a stay. The Court highlighted that the Missouri Supreme Court's refusal to stay the execution effectively denied Blair the opportunity for federal habeas corpus review, contrary to established precedents, including McDonald v. Missouri and Williams v. Missouri, which mandate stays when federal judicial review is pending. The decision underscored the responsibility of state courts to allow federal review before carrying out executions. Justice Blackmun emphasized the constitutional entitlement of every defendant in a state court facing the death penalty to have their direct review completed before execution, regardless of the severity of their offense. He criticized the Missouri Supreme Court for failing to grant a stay of execution, reiterating his earlier guidance that he would issue stays upon proper application if the state court neglected its responsibilities. The petitioner had indicated to the Missouri Supreme Court that federal habeas review was sought based on a relevant Eighth Circuit decision, which held that the use of death-qualified juries violated constitutional rights. Despite this, the Missouri Supreme Court denied the stay, highlighting a procedural entitlement for the petitioner to receive a stay of execution. Habeas corpus, as the exclusive federal remedy for testing the legality of a state prisoner's incarceration or sentence, does not reevaluate guilt but addresses fundamental trial unfairness and constitutional infringements. The right to petition for habeas corpus is constitutionally guaranteed, and condemned prisoners must have the opportunity for review before execution, reinforcing the necessity of procedural safeguards in capital cases. Additionally, the excerpt notes recent complaints from state courts about perceived federal overreach into state judicial matters. Federal courts adhere to the principle of comity, which necessitates that state courts be given the opportunity to fulfill their responsibilities. The Missouri Supreme Court holds a crucial role in scheduling executions as mandated by state law, and it is expected to grant stays of execution when appropriate requests are made. Although comity is not directly at issue in this case, the integrity of this principle may be compromised if the Missouri Supreme Court neglects its duty regarding stay requests during federal reviews. Given the Missouri Supreme Court's failure to act, the Court has decided to intervene, granting the petitioner's request for a stay of execution, which was originally scheduled for March 20, 1985, until the habeas corpus petition is resolved.