CULLEN v. PINHOLSTER

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Case Basics
Docket No. 
09-1088
Petitioner 
Vincent Cullen, Acting Warden
Respondent 
Scott Lynn Pinholster
Decided By 
Advocates
(Supervising Deputy Attorney General of California, for the petitioner)
(for the respondent)
Term:
Facts of the Case 

A California state court convicted Scott Lynn Pinholster of double murder and sentenced him to death. After exhausting his state court remedies, he petitioned for habeas corpus relief in a California federal district court, arguing that he was denied effective assistance of counsel at both the guilt and sentencing phases of his trial. The district court upheld Pinholster's conviction but granted habeas relief on his death sentence. The district court affirmed the conviction but reversed the grant of habeas relief on the death sentence.

The U.S. Court of Appeals for the Ninth Circuit reversed the lower court order, holding that the denial of habeas relief during the guilt phase was appropriate, but not during the penalty phase. The court noted that Strickland v. Washington requires trial counsel to investigate mitigating evidence at the penalty phase. Here, the court reasoned that Pinholster's counsel failed meet to meet his obligations.

Question 

Can a federal court overturn a state criminal conviction on the basis of facts the defendant could have alleged, but did not, in state court?

Conclusion 
Decision: 5 votes for Cullen, 4 vote(s) against
Legal provision: ADEPA

No. The Supreme Court reversed the lower court order in an opinion by Justice Clarence Thomas. Limiting "review to the state-court record is consistent with our precedents," Thomas wrote for the 5-4 majority. Justice Stephen Breyer filed a partial dissent in which he contended that "I do not join Part III, for I would send this case back to the Court of Appeals so that it can apply the legal standards that Part II announces to the complex facts of this case." Justice Sonia Sotomayor, joined by Justices Ruth Bader Ginsburg and Elena Kagan, dissented in full. "Some habeas petitioners are unable to develop the factual basis of their claims in state court through no fault of their own," Sotomayor argued.

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CULLEN v. PINHOLSTER. The Oyez Project at IIT Chicago-Kent College of Law. 04 April 2014. <http://www.oyez.org/cases/2010-2019/2010/2010_09_1088>.
CULLEN v. PINHOLSTER, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2010-2019/2010/2010_09_1088 (last visited April 4, 2014).
"CULLEN v. PINHOLSTER," The Oyez Project at IIT Chicago-Kent College of Law, accessed April 4, 2014, http://www.oyez.org/cases/2010-2019/2010/2010_09_1088.