I have been too busy the past couple of days to notice that the Supreme Court issued their first opinion of the October 2009 Term. It was in a capital habeas case called Corcoran v. Levenhagen. The opinion can be found here. The Court vacated a Seventh Circuit decision denying habeas and remanded for further proceedings.
Although it was a win for the habeas petitioner, there is not much in it substantively for either capital or non-capital habeas petitioners.
However, it's a good decision for all habeas petitioners generally from a procedural point of view.
Here's what happened. Petitioner raised four claims in his petition. The district court granted relief on one claim -- an ineffective assistance of counsel claim -- but did not address the other three, finding that they were mooted out by the grant of relief on the ineffectiveness issue. The Seventh Circuit reversed the district court on the ineffectiveness issue and denied habeas relief without mentioning petitioner's other three claims.
The Supreme Court vacated the Seventh Circuit decision, concluding that the circuit court should not have denied the petition without any mention of the other claims. It held that the court "should have permitted the District Court to consider Corcoran’s unresolved challenges to his death sentence on remand, or should have itself explained why such consideration was unnecessary."
Although the result seems obvious, it does appear to be a novel statement from the Supreme Court as to how to proceed in this type of situation. The Court does not cite to any law or rule to support its decision. Rather, this decision appears to be the Court exercising its supervisory role over the lower courts.
So a good start for the 2009 Term.
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