Narrative Opinion Summary
The case involves a California state prisoner, convicted of first-degree murder in 1989, who sought to file a second or successive habeas corpus petition under 28 U.S.C. § 2244(b), following the denial of his latest petition by the California Supreme Court. The Ninth Circuit Court of Appeals reviewed and denied the application, citing that previously presented claims were barred, and new claims failed to meet the statutory criteria for undiscoverable factual bases or new constitutional law. Morales's claims, centered on alleged perjured testimony by an informant and prosecutorial misconduct, were unable to demonstrate the requisite prima facie showing for a new petition. Further, his assertion of actual innocence was undermined by corroborative testimony from other witnesses that supported the jury's original findings. The court emphasized that Morales had been aware of the issues with the informant's testimony since 1993, rendering his delay unjustifiable. Consequently, the court denied the request for a stay of execution and reaffirmed the validity of the original conviction and sentence.
Legal Issues Addressed
Actual Innocence Standard in Habeas Corpus Petitionssubscribe to see similar legal issues
Application: Morales's assertion of actual innocence, particularly regarding the lying-in-wait circumstance, was insufficient as other evidence corroborated the jury's findings of culpability.
Reasoning: Under Schlup v. Delo, a substantive 'Herrera-type claim' must demonstrate that new facts incontrovertibly establish Morales's innocence, a burden he fails to meet.
Impact of Perjured Testimony on Habeas Corpus Petitionssubscribe to see similar legal issues
Application: The court found that allegations of perjured testimony by informant Samuelson did not warrant granting a second or successive petition as similar arguments had been previously dismissed.
Reasoning: Claim One fundamentally reiterates prior challenges to Samuelson's testimony and alleged prosecutorial misconduct, resulting in its dismissal under 28 U.S.C. 2244(b)(1).
Second or Successive Habeas Corpus Petitions under 28 U.S.C. § 2244(b)subscribe to see similar legal issues
Application: The court denied Morales's application for a second or successive habeas petition as the claims were previously raised or failed to meet the criteria for new claims under § 2244(b).
Reasoning: Claims previously presented in a federal habeas petition are dismissed under § 2244(b)(1). Under § 2244(b)(2), new claims must either rely on a new constitutional law or show that the factual basis for the claim was previously undiscoverable and would establish actual innocence.
Standard for New Claims in Habeas Corpus Petitionssubscribe to see similar legal issues
Application: Morales's claims did not satisfy the requirements for new claims as they failed to demonstrate that the factual basis was previously undiscoverable with due diligence.
Reasoning: Even if the claims were not previously presented, the application for the SOS petition would still be denied as Morales has not demonstrated a prima facie case that he could not have discovered the factual basis for these claims earlier with due diligence.