Narrative Opinion Summary
In this federal habeas corpus proceeding, a California prisoner, convicted of first-degree murder with special circumstances, sought a stay of execution and permission to file a successive habeas petition under 28 U.S.C. § 2244(b). His conviction was upheld by the California Supreme Court and the U.S. Supreme Court denied certiorari. The prisoner alleged prosecutorial misconduct and perjured testimony by an informant, asserting these claims were newly discovered. However, the court found these issues had been previously raised or failed to meet the due diligence and actual innocence standards required for a successive petition. The court also rejected his claim of actual innocence, citing substantial evidence supporting the jury's decision, including multiple witness accounts of the premeditated nature of the crime. The application for a successive petition and a stay of execution was denied, as were his requests to recall the mandate and present new evidence, failing to demonstrate that no reasonable juror would have imposed the death penalty. Consequently, the court upheld the denial of relief, emphasizing the stringent legal standards governing successive habeas petitions and claims of actual innocence.
Legal Issues Addressed
Actual Innocence under Herrera v. Collinssubscribe to see similar legal issues
Application: Morales's claim of actual innocence concerning the special circumstance of lying in wait was rejected due to ample evidence supporting the jury's decision.
Reasoning: Claim Four is framed by Morales as a claim of actual innocence, referencing Herrera v. Collins, which imposes a stringent burden of proof.
Perjured Testimony and Prosecutorial Misconductsubscribe to see similar legal issues
Application: Morales's claims of perjured testimony and prosecutorial misconduct were dismissed as they were either previously raised or failed to meet due diligence and actual innocence standards.
Reasoning: Claims Two and Three mirror arguments previously rejected in Morales' earlier habeas proceedings, asserting that the state presented false testimony from a government informant in exchange for prosecutorial favors.
Procedural Default and Due Diligencesubscribe to see similar legal issues
Application: The court found that Morales failed to show due diligence in uncovering the factual basis for his claims, as he had known about the issues since 1993.
Reasoning: Even if Claims One, Two, and Three had not been presented before, Morales fails to demonstrate due diligence in uncovering the factual basis for these claims, as he has been aware of the issues with Samuelson's testimony since 1993.
Standard for Stay of Executionsubscribe to see similar legal issues
Application: The court denied Morales's request for a stay of execution because the new evidence presented did not meet the standard of showing that no reasonable juror would have sentenced him to death.
Reasoning: If considered as a procedural 'gateway' claim under Schlup v. Delo, Morales must provide clear and convincing evidence that no reasonable juror would have sentenced him to death based on the new evidence, a standard he fails to meet.
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 successive habeas corpus petition as it did not meet the statutory requirements for a new constitutional rule or demonstrate actual innocence.
Reasoning: Under § 2244(b), Morales can only file a successive petition if it shows a prima facie case meeting the statutory requirements. Claims presented in prior petitions are dismissed under § 2244(b)(1), while § 2244(b)(2) allows new claims only if they rely on a new constitutional rule or if the applicant demonstrates due diligence and actual innocence based on new facts.