Narrative Opinion Summary
The case revolves around Ernest Lee Johnson, convicted of three counts of first-degree murder and initially sentenced to death. Johnson's appeals included claims of intellectual disability and challenges to Missouri's lethal injection protocol as cruel and unusual punishment. The court examined his intellectual disability claim under Missouri law and DSM-5 criteria, concluding that Johnson did not meet the necessary standards. His claims regarding the execution method were also dismissed due to insufficient evidence linking Pentobarbital to his alleged medical risk during execution. Johnson's proposal for a firing squad as an alternative execution method was rejected as he failed to demonstrate its practicality or risk reduction compared to lethal injection. The court emphasized procedural rules against revisiting claims in successive habeas petitions. Ultimately, the court denied Johnson's habeas corpus petition, finding him eligible for the death penalty. The decision underscores both the legal standards for establishing intellectual disability in capital cases and the stringent requirements for challenging execution methods under the Eighth Amendment.
Legal Issues Addressed
Burden of Proof in Intellectual Disability Claimssubscribe to see similar legal issues
Application: The court upheld jury instructions requiring Johnson to prove his intellectual disability, rejecting his claims that the instructions were misleading.
Reasoning: The jury instruction requiring Johnson to prove his intellectual disability was appropriate.
Eighth Amendment and Alternative Methods of Executionsubscribe to see similar legal issues
Application: Johnson's proposal of a firing squad as an alternative method of execution was deemed insufficient, as he failed to demonstrate its feasibility or that it would reduce risks compared to the current method.
Reasoning: The court finds Dr. Zivot's affidavit insufficient to prove that Johnson is likely to endure a painful seizure during execution.
Habeas Corpus and Successive Claimssubscribe to see similar legal issues
Application: The court addressed the procedural limitations of successive habeas petitions, emphasizing the burden of proof lies with the petitioner and that successive claims face a presumption against revisiting previously litigated issues.
Reasoning: Habeas review does not allow for revisiting claims previously raised and that framing his claim as actual innocence inherently relates to the Eighth Amendment and Atkins v. Virginia.
Intellectual Disability and Capital Punishmentsubscribe to see similar legal issues
Application: The court evaluated Johnson's intellectual disability claims against Missouri law and DSM-5 criteria, ultimately finding insufficient evidence to establish intellectual disability.
Reasoning: Johnson fails to demonstrate impairments in any of the three adaptive functioning domains outlined in the DSM-5, leading to the conclusion that he does not meet the criteria for intellectual disability.
Method of Execution and Cruel and Unusual Punishmentsubscribe to see similar legal issues
Application: Johnson challenged the use of Pentobarbital citing medical concerns, but the court found his claims insufficient due to lack of evidence linking the drug to his purported risk of seizures.
Reasoning: Johnson has not sufficiently proven that the risk of seizure is 'sure or very likely' to occur.