Narrative Opinion Summary
The case involves Lawrence Lee Buxton, who, after being convicted of capital murder and sentenced to death in Texas, pursued relief through a second federal habeas corpus petition under 28 U.S.C. Sec. 2254. Buxton sought to vacate his conviction and stay his execution, initially set for February 26, 1991. His conviction stemmed from a 1980 robbery during which a victim was fatally shot. Buxton's conviction was upheld by state and federal courts, including the denial of certiorari by the U.S. Supreme Court. In subsequent habeas proceedings, Buxton raised constitutional claims alleging violations of his Sixth, Eighth, and Fourteenth Amendment rights, ineffective assistance of counsel, and procedural deficiencies. However, both the Texas Court of Criminal Appeals and the district court found Buxton's claims procedurally barred due to his attorneys' failure to object at trial. The federal court adhered to the adequate and independent state ground doctrine, denying Buxton's certificate of probable cause for appeal and his motion for a stay of execution. The court concluded that Buxton did not demonstrate a substantial violation of federal rights, and his claims lacked merit, culminating in the denial of relief.
Legal Issues Addressed
Adequate and Independent State Ground Doctrinesubscribe to see similar legal issues
Application: The federal court respected the Texas Court of Criminal Appeals' procedural bar decision as it was an adequate and independent state ground.
Reasoning: The adequate and independent state ground doctrine mandates that federal courts respect such state decisions, allowing them to invoke a procedural bar without negating federal law considerations.
Certificate of Probable Cause (CPC) for Appealsubscribe to see similar legal issues
Application: The court denied Buxton's application for a CPC, as he failed to demonstrate a substantial showing of a denial of a federal right.
Reasoning: The district court denied his requests and also refused to grant a certificate of probable cause (CPC) for appeal.
Federal Habeas Corpus under 28 U.S.C. Sec. 2254subscribe to see similar legal issues
Application: Buxton filed a federal habeas corpus petition seeking to vacate his capital murder conviction and stay his execution.
Reasoning: Lawrence Lee Buxton, on death row in Texas, filed a second federal habeas corpus petition in the Southern District of Texas on February 22, 1991, seeking to stay his execution set for February 26, 1991, and to vacate his capital murder conviction under 28 U.S.C. Sec. 2254.
Ineffective Assistance of Counselsubscribe to see similar legal issues
Application: Buxton claimed ineffective assistance of counsel, but the court found no deficiency or prejudice in his counsel's performance under the Strickland v. Washington standard.
Reasoning: Claims of ineffective assistance of counsel are evaluated using the two-prong standard from Strickland v. Washington.
Procedural Default in Habeas Corpus Claimssubscribe to see similar legal issues
Application: Buxton's claims were procedurally barred due to his trial attorneys' failure to object at trial, precluding him from raising these issues in habeas corpus applications.
Reasoning: Both the Texas Court of Criminal Appeals and the district court determined that Buxton's claims were procedurally barred because his trial attorneys did not object to the absence of an 'anti-parties' charge...
Stay of Execution Criteriasubscribe to see similar legal issues
Application: The court evaluated four factors and determined that Buxton did not present a substantial case on the merits to justify a stay of execution.
Reasoning: In considering a stay of execution, four factors must be evaluated: (1) likelihood of success on the merits; (2) showing of irreparable injury if the stay is not granted; (3) potential harm to other parties; and (4) public interest.