Phillip Reese has this post at the Sacramento Bee, noting a disturbingly sharp disparity in the arrest rate for one group in California, a rate nearly triple the state average.

News Scan

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Habitual Felon to be Charged with Multiple Murders: A California man with a lengthy criminal past has been arrested and is expected to be charged later today with several counts of murder.  The Associated Press reports that 34-year-old Alexander Hernandez is believed to be responsible for killing four people and wounding several others over five days across Los Angeles County.  Hernandez has already been charged with one count of capital murder, two counts of attempted murder, three counts of animal cruelty, and is expected to be charged with three more counts of first-degree murder.  If found guilty, Hernandez faces a possible death sentence.  

Convicted Murderer Kills Again: Authorities in Missouri say that an inmate has died from injuries he sustained at the hands of his cellmate, a convicted murderer.  The Associated Press reports that 35-year-old Mark Melton was assaulted in his cell earlier this month and eventually died from his injuries last weekend.  Authorities believe his cellmate, who is serving a sentence for second-degree murder was responsible for his death and have classified the incident as a homicide.

Oregon Killer Awaits Parole Decision: An Oregon man convicted of raping and murdering his 16-year-old classmate more than two decades ago is awaiting a decision from the state's parole board on whether or not he will be released from custody.  KOIN 6 News reports that Conrad Engweiler was 15 at the time of the killing, and is one of five Oregon men who committed aggravated murder as juveniles before mandatory sentencing guidelines had been established.  Engweiler was sentenced in 1991 to life with a minimum of 30 years.  The parole board is expected to make a decision on his release within weeks.

Fools, Damned Fools, and Clients

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Michael Barone writes in the Washington Examiner:

"About half the practice of a decent lawyer consists in telling would-be clients that they are damned fools and should stop." So supposedly said Elihu Root, New York lawyer and secretary of war and of state, and U.S. senator from 1909 to 1915.

Today it seems that many liberal "would-be clients" are in desperate need of what Root called "a decent lawyer."

Take Texans for Public Justice, the so-called public interest group that has been pushing for the indictment of Gov. Rick Perry by a grand jury at the urging of special prosecutor Michael McCrum.

The basis for the indictment is, in the words of liberal New York Magazine writer Jonathan Chait, "unbelievably ridiculous."

New Chief for ICE?

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Devlin Barrett reports for the WSJ that Sarah Saldaña, US Attorney for the Northern District of Texas, "is the leading candidate to run the Immigration and Customs Enforcement agency, according to people familiar with the discussions."

ICE is one of the agencies created in the post-9/11 reshuffle of homeland security organization.  It has many of the functions previously performed by the old Immigration and Naturalization Service.

And the story has this nugget:

Ms. Saldaña got her current job after an unusual political standoff in which her nomination to become U.S. attorney was backed by Sen. John Cornyn (R., Texas) and opposed by some Democrats in the Texas congressional delegation.

Arizona Primary

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Arizona had its primary election yesterday.  Mark Brnovich won the Republican nomination for Attorney General, defeating incumbent Tom Horne, Alia Beard Rau reports for the Arizona Republic.

I lauded Horne on this blog for moving forward with a "fast track" application for Arizona's capital cases in federal habeas corpus (here and here), but unfortunately the follow-through has been lacking.  I expect Brnovich to take up the fight if he wins the general election.  (He and I serve together on the Federalist Society's Criminal Law Practice Group Executive Committee, BTW.)

The general election is not a foregone conclusion, though.  The race was close last time, the Democratic nominee had no primary opponent, and she has a formidable warchest.

In the Governor's race Doug Doucey has taken the Republican nomination.  I haven't followed that race, but Doucey has endorsements from people whose judgment I respect.  His campaign website is nearly devoid of useful information on his positions, as most campaign websites are these days.
UC Irvine Law Dean Erwin Chemerinksy has this op-ed in the NYT, titled "How the Supreme Court Protects Bad Cops." 

Chemerinsky is upset about the doctrine of qualified immunity in civil suits against police officers for excessive force.  Okay.  Although I generally support it, at times I have had some qualms about some aspects and applications of that doctrine myself.  But just looks at what he says to support this argument.

Arbitrariness, Expense and Delay

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Three of  the major emerging themes in the anti-death penalty movement are arbitrariness, expense and delay.  The first and third of these are, as I understand it, the principal arguments in the district court's opinion in Jones v. Chappell, about which Kent has written extensively.

I am not in this post going to attempt any extended analysis of these themes; instead, I'm going to do the really, really short take on the first*  --  the claim (see, e.g., here) that the death penalty is carried out so infrequently that in has become arbitrary in the constitutional or morally disabling sense.  

*In later posts I'll take on the other two.

Jones v. Chappell Appeal

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Last week I noted the appeal in Jones v. Chappell, the case holding that because of the delays in carrying out justice in the worst murder cases in California we must now forgo that justice altogether. The docket number in the Ninth Circuit is 14-56373.  The appellant's opening brief is due December 1.  The answer brief is due December 29.  The reply brief is due January 12.  These are all Mondays.

Some people have asked me about a stay.  There is nothing to stay.  There is no injunction affecting other cases.  There is no final judgment in this case.  This is just a ruling on one claim in one case.  To the extent the judge's order purports to vacate Jones's death sentence directly, it is void.  A federal district court judge has no authority to vacate a judgment in a state criminal case as such.  He can only issue a conditional release order, saying that the warden must release a person unless he is retried or resentenced, and the judge in this case has not done that yet.

BTW, Ninth Circuit case 14-56302 is the Soos/Justice appeal noted here, and that case will surely go away shortly.  Update: Today Mr. Soos and Dr. Justice filed their response to the Court of Appeals' order to explain what the heck they are doing appealing a case to which they are not parties.

News Scan

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CA Man Attacks Aunt Hours After Jail Release: A Fresno, CA man has been arrested and is facing charges of assault with a deadly weapon after authorities say he attacked his aunt with a hammer just hours after being released from county jail.  ABC 30 Action News reports that Anthony Palomino had been arrested last week after breaking into cars at his relative's funeral, but was released early from the Fresno County Jail due to overcrowding.  Authorities say after he was released, Palomino attacked his aunt with a hammer leaving her with a black eye, broken cheek bone, and 19 staples in her head.  He is being held in county jail on $25,000 bail.

Killers Plead Guilty to Avoid Death Penalty: A Pennsylvania couple has agreed to plead guilty to second-degree murder in the alleged thrill-killing of a man last year in order to avoid a possible death sentence.  Nikki Krize of WNEP News reports that Miranda and Elytte Barbour, also known as the 'Craigslist killers', met their victim online and lured him into meeting them because they wanted to murder someone together.  The couple has also claimed responsibility in 20 other murders in different parts of the U.S., however, authorities have yet to confirm them.  The couple will be sentenced next month, likely to life in prison without the possibility of parole.

California's Firearm Wait Period Deemed Unconstitutional: A federal judge has ruled in favor of overturning part of a California law that mandated a 10-day waiting period for gun buyers, calling the legislation a violation of the Second Amendment.  KCRA Sacramento reports that the mandatory waiting period will no longer apply to individuals who already own firearms, however, first time gun buyers will still be required to undergo a background check and wait the mandatory 10 days.  The state attorney general has yet to announce whether or not she will appeal the ruling.

Evil, Part II

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Kent notes that WaPo columnist Richard Cohen has discovered the existence of evil. As Kent observes, this is progress.  Three years ago, Mr. Cohen took a more relativist approach.  The subject then was nothing like the grotesque beheading of a hostage (it was, instead, the behavior of the very unfortunately named Congressman Weiner), but relativism quickly balloons once it escapes, so I went after Mr. Cohen with both barrels in my comment to Kent's post.

Still, progress is progress and clarity is clarity, and I'm happy to see them.  Perhaps, in a different life, I'll see some on the editorial page of the New York Times.

Evil

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After 9/11, it briefly became acceptable across the ideological spectrum to speak of "evil."  Usually, the pseudosophisticates who dominate academia, journalism, and the political left consider it the mark of a rube to speak in terms of good and evil.  Being "advanced" requires moral relativism which requires understanding and compassion for people who commit horrendous crimes.  Murder and rape are "antisocial behavior," not evil acts.

Richard Cohen is a columnist for the WaPo who leans left but has more sense than most of his ilk.  In this column, he dares to use the e-word:
The sitting Governor of Colorado, John Hickenlooper, is in a heated re-election campaign.  One of the issues is his handling of the case of convicted multiple killer John Dunlap.  

Dunlap gunned down four people in a Chuck E. Cheese in Aurora in 1993.  He was sentenced to death, and the sentence has been affirmed after the usual multiple layers of review.  Nonetheless, and despite the fact that Hickenlooper originally ran for office as a death penalty supporter, he granted Dunlop a "temporary reprieve" earlier this year, saying that Dunlop would not be executed while he was in office.

In a TV interview with CNN, now reported by the Denver Post, Hickenlooper said that, should his pro-death penalty opponent, Rep. Bob Beauprez, win, he would consider granting "full clemency" to Dunlop.

It's hard to know where to begin with this story.


Pretrial Habeas Corpus and Gov. Perry

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Once upon a time, the use of habeas corpus in criminal cases was almost entirely pretrial.  A person jailed pending trial for alleged conduct that he contended was not a crime could get that issue reviewed via habeas corpus.  The most famous American case involved two men accused in the Aaron Burr conspiracy.  See Ex parte Bollman and Swartwout, 8 U.S. 75 (1807).  The writ could be used post-trial to attack the jurisdiction of a court of limited jurisdiction, such as a court-martial of a defendant who claimed to be a civilian, but collateral attack via habeas corpus on a conviction by a court of general jurisdiction was simply not available.  It was over 40 years after the formation of the federal courts before anyone tried, and the attempt was swiftly shot down in Ex parte Watkins, 28 U.S. 193 (1830).

Today the situation is very much the opposite.  We don't see a lot of pretrial habeas corpus these days, but Texas Governor Rick Perry is doing it old school.  Eugene Volokh has this post with a link to the application. Perry is in "custody," a jurisdictional requirement for habeas corpus, because he is out on bond.

Taranto on Obama's Ferguson Statement

Catching up on some stuff that happened while I was out of town, I found an interesting example of the political cross-currents in the Ferguson, Missouri matter.  James Taranto of the WSJ is not a big fan of President Obama, to put it mildly.  He does, though, give the President high marks for his statement last week in this column.

Multiple investigations are under way into the circumstances under which Michael Brown was killed. They must proceed deliberately, in accordance with the rule of law. "I have to be very careful about not prejudging these events before investigations are completed because, although these are issues of local jurisdiction, the [Department of Justice] works for me and when they're conducting an investigation I've got to make sure that I don't look like I'm putting my thumb on the scales one way or the other," the president said.

People in positions of authority have an obligation to conduct themselves with reason and restraint. Whether or not the Ferguson police have lived up to that duty, the president, in his public statements on the crisis, has.

News Scan

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Chicago Experiencing Crime Drop: Police in Chicago, Illinois have announced that the city has experienced a sharp decrease in crime as more residents have begun arming themselves after the state started granting concealed carry permits earlier this year.  Kelly Riddell of The Washington Times reports that the city has seen a decrease in burglaries and robberies, and Chicago's homicide rate was at a 56-year low.  Richard Pearson, executive director of the Illinois State Rifle Association, believes that the decreases are directly linked to the state allowing citizens to carry concealed weapons. 

Murderer Avoids Death Penalty: A Florida man will spend the rest of his life behind bars after being charged in multiple killings.  Larry Hannan of the Florida Times-Union reports that 29-year-old DeShawn Green was able to avoid a death sentence for the third time last week after prosecutors elected to drop first-degree murder charges out of fear that a possible acquittal could jeopardize his prior two murder convictions.  Green was originally sentenced to death for a 2009 murder but the judge overruled the jury and gave him life without parole instead.

TX National Guard to Begin Patrolling Border: Roughly 1,000 Texas National Guard troops have been deployed to the Mexican border in an effort to combat escalating crime rates in the area.  Reuters reports that Texas Governor Rick Perry advised the troops that they were being deployed to the border region to deter criminal activity. Perry estimates that deploying the troops will cost the state at least $12 million a month. Texas border cities have been overwhelmed with immigrants flooding the state's borders since late 2013, causing escalating crime.

The Only Thing That Actually Counts

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The shooting in Ferguson, Mo. has been the launching pad for all manner of expounding about pre-existing agendas.  Libertarians have used it to urge the disarming of the police (called "demilitarization" for their present purposes); liberals have used it to push for legalizing dope; anti-white racists have used it to demand reparations ("reparations" being the word that radicals of one race use to promote appropriating money they did nothing to earn from people of a different race who did nothing to bring about the practices they condemn).

All this is the expected, if not exactly wholesome, reaction of a society that encourages free speech.  But it deflects  --  and is largely designed to deflect  -- from the one thing that actually counts.

There's Only So Much You Can Do

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I've done my share of criticizing the defense bar.  As I see the world, the problem is (1) the client is almost always factually guilty, therefore (2) the only way to an acquittal on the merits is through some sort of sleight-of-hand, but (3) doing sleight-of-hand day after day doesn't seem to be a real wholesome way to conduct one's career.

That said, most defense lawyers I know are good human beings, and sometimes they really are the heroes of civil liberties they claim.  Even when doing the routine case, however, the heart of the problem isn't the lawyer.  It's the client.

I mean, what exactly are you supposed to do when the fellow who shows up in your office is this guy?

Terrorist Horror, Then Golf

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The title of this entry is taken from yesterday's headline in that right wing rag, the New York Times.  It refers, of course, to President Obama's ostensibly somber and angry news conference about the videotaped beheading of an American citizen by Islamic butchers, followed forthwith by a few rounds on the links.

As the Times points out, the contrast was a bit much even for the President's usual allies:

Jones v. Chappell Appealed

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The California Attorney General today filed a notice of appeal in the Jones v. Chappell case.

Earlier posts on this case:

The Lackey Claim, Again

Summing up the Jones Death Penalty Case

Why Jones v. Chappell is Wrong, Part 2

Why Jones v. Chappell is Wrong, Part 3 -- Teague v. Lane

Time to Appeal Jones v. Chappell, Ms. Harris

Does a California District Attorney Have Standing to Intervene in a Federal Habeas Corpus Case?

Further Strange Developments in Jones v. Chappell

The Attorney General said in a press release, "I am appealing the court's decision because it is not supported by the law, and it undermines important protections that our courts provide to defendants. This flawed ruling requires appellate review."  Undermines important protections?  Well, certainly "not supported by the law," "flawed," and "requires appellate review" are correct.  With apologies to Meatloaf, three out of four ain't bad.

News Scan

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Convicted Sex Offender Charged with Murder: Police in Washington have arrested and charged convicted sex offender Richard Atkisson with two counts of aggravated murder for the alleged killing of his two roommates this past weekend.  KOMO News reports that Atkisson admitted to police that he beat the two men to death after an argument escalated in their home.  Atkisson was sentenced to 23 years behind bars in 1993 for rape and also had prior convictions for burglary and failing to register as a sex offender, prosecutors also say Atkisson had an active warrant out for his arrest in California for violating his court-ordered supervision.

Arias Granted Delay in Penalty Phase Retrial: An Arizona judge has delayed the penalty phase retrial of convicted killer Jodi Arias until September 29.  Brian Skoloff of the Associated Press reports that Arias, who is acting as her own attorney, asked the judge to delay her trial in order to have more time to prepare.  Arias was convicted last year of killing her ex-boyfriend and faced a possible death sentence, however, the jury presiding over her case was unable to reach a unanimous sentencing decision.  Under Arizona law, prosecutors are allowed to hold a second penalty phase trial with a new jury in death penalty cases-if this jury also fails to reach a unanimous decision, Arias will automatically be sentenced to 25 years to life. 

Sex Offender Charged in Brutal Attack: A New York man has been charged with attempted murder after authorities say he pulled a woman into the woods and repeatedly stabbed her.  CBS Albany reports that 50-year-old James Sayers, a convicted sex offender, followed the woman for nearly a mile before attacking the woman and stabbing her so many times that his knife eventually broke.  A warrant had been issued for Sayers arrest shortly after the attack when his parole officer discovered that he had removed his electronic monitoring device, he had just been released from prison and put on parole in May after serving a sentence for robbery.


DOJ's Version of Unbiased Justice

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My friend Paul Mirengoff at Powerline has a depressing and ominous assessment of the chance that Officer Darren Wilson, the Missouri cop who shot unarmed but huge 18 year-old Michael Brown, can get a fair shake from the federal grand jury looking into the case.

Eric Holder's Justice Department is in Missouri, some 50 strong according to Megyn Kelly, to investigate the shooting of Michael Brown and to decide whether to charge police officer Darren Wilson with civil rights crimes. The investigation and decision is in the hands of the Criminal Section of the Civil Rights Division.

How much confidence can Americans have in the fairness and objectivity of this unit? The answer, I submit, is little if any.

Christian Adams at PJ Media has been covering the Criminal Section of the Civil Rights Division for years. PJ Media had to file a lawsuit to obtain the resumes of the lawyers Holder has brought into that group. According to Adams, it turned out that every one of his hires is a left-wing activist, and that some have histories of anti-police activity. 


What follows is a hair-raising rundown of the background of the lawyers who will be running the grand jury.  The short of it is that they're a bunch of far left ideologues.  

If you thought the Rick Perry indictment was a creature of politics, you're right. But I fear it was just a rehearsal.

" 'Curiouser and curiouser!' Cried Alice (she was so much surprised, that for the moment she quite forgot how to speak good English)." -- Lewis Carroll

The strange case of Jones v. Chappell, got a little stranger on August 11.  It was curious enough with the district judge's order, noted here and in several posts since.  Then the PACER docket shows a notice of appeal filed August 11 by Jones, which is curious, since the ruling appealed from is in his favor.  Even more curious is that when you download the actual document it isn't by Jones at all.  Or by Chappell.  The appeal is filed by "Mr. Emery D. Soos, Jr. and Dr. Robert V. Justice, Citizens of the State of California."

Um, nice try, guys.  The Court of Appeals is not amused.  "By August 26, 2014, non-parties Emery Soos and Robert Justice shall move in this Court for voluntary dismissal of this appeal or explain in writing why the appeal should not be dismissed for lack of jurisdiction due to their lack of standing to appeal."

August 26, interestingly, is the day after the deadline for the actual respondent to appeal, and given that there is not a single legitimate reason not to there should be a bona fide appeal in the Ninth Circuit on that date.

News Scan

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Governor Signs Execution Warrant: Pennsylvania Governor Tom Corbett has signed an execution warrant for convicted murderer Michael Parrish.  Alison Burdo of NBC 10 reports that 28-year-old Parish was found guilty and sentenced to death in May 2012 for the murder of his girlfriend and their 19-month-old child.  Parrish is scheduled to die by lethal injection on October 14, 2014, Pennsylvania hasn't executed a death row inmate since July 1999.

Convicted Cop Killers Denied Parole: The Ohio Parole Board has once again denied release for two men convicted of murdering a Cincinnati Police Officer in 1978.  Brad Evans of WLWT News reports that both men were originally sentenced to death for the crime, but that sentence was reduced to life behind bars by the state's Supreme Court.  Both men will be eligible for parole again in May 2019.

CA High Court Upholds Death Sentence: In a unanimous ruling, California's Supreme Court ruled in favor of upholding the death penalty verdict for convicted killer Gene McCurdy.  Lewis Griswold of the Fresno Bee reports that McCurdy was found guilty of kidnapping and murdering an 8-year-old girl nearly two decades ago.  McCurdy appealed his ruling based on the claim that statements given to detectives during the interview process should have been suppressed and that instructions given to the jury prior to sentencing were faulty.


Where Have All the Liberals Gone?

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People of my generation well remember the haunting anti-war song "Where Have All the Flowers Gone" written by Pete Seeger and popularized by Peter, Paul and Mary. It was running through my head this morning, and got me to thinking, as I mulled the media's coverage of the shooting in Ferguson, Mo.:  Where have all the liberals gone?

In days of yore, when there was a notorious homicide or some other infamous episode, what I used to hear was

--  "No rush to judgment!"

--  "In America, everyone is presumed innocent."

--   "We can't try this case in the press."

--  "No trial by mob."

I'm just not hearing that at all these days. 

Where have all the liberals gone?


Actual Innocence and Habeas Corpus

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Is a claim that a convicted prisoner is actually innocent of the crime, by itself without any claim that the trial was procedurally unfair, a ground for relief in habeas corpus?  That question remains unanswered.  Today in Jones v. Taylor, No. 13-36202, the Ninth Circuit reversed a district court's grant of relief to an Oregon prisoner convicted of intrafamily sexual abuse.  As sometimes happens in such cases, the witnesses (who are family of the defendant) recanted.  The opinion by Judge Tashima skips the question of whether a sufficient showing of actual innocence can be a ground for habeas relief and says that this showing doesn't make it.

This is a common outcome in such cases.  The Supreme Court seemed poised to decide the "actual innocence" question in Herrera v. Collins, 506 U.S. 390 (1993), but when it took a good, hard look at the evidence it saw that it fell "far short" of anything that might conceivably warrant overturning a conviction.  In the infamous Troy Davis case, the high court took the extraordinary step of sending an original habeas petition to a district court for fact-finding on innocence, where the district judge found that Davis's claim of innocence was "smoke and mirrors." 

The Other Side of the Story in Ferguson

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I take press reports with a grain of salt, not because I think reporters are biased (although some certainly are), but because I much prefer facts about alleged crimes to be proved by the rigors of presentation in court, in particular oath-taking and cross-examination.  This is one reason that, for example, I put no great stock in one-sided "reports" that, 22 years after the fact, Cameron Todd Willingham has been "proved" innocent by "more advanced" scientific testing conducted by his partisans without oversight, scrutiny, or adversarial process of any kind.

It is with this skepticism in mind that I bring you this report from the New York Post:  "A Dozen Witnesses Say Ferguson Teen Attacked Cop Before Shooting".  There is also a report out that the cop, Officer Darren Wilson, suffered a facial fracture as a result of being attacked by the teenager he shot.

If these reports are true, it's very difficult to see how a scrupulous prosecutor can indict Wilson.

Unfortunately, with the politically edgy Civil Rights Division on the case, the operative word here is "scrupulous." 

We shall see.

UPDATE:  The original source for this story, St. Louis Post-Dispatch reporter 
Christine Byers, has been on family and medical leave since March, and has tweeted that the story does not appear in the paper because "it did not meet standards for publication." This makes me happy that I started this entry by reiterating my skepticism about about media reports.  Of course the story may still be true; we should find out more in the days to come. 

Ryan v. Hurles Returns to SCOTUS

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Arizona's attempt to reinstate the death sentence of murderer Richard Hurles is back in the U.S. Supreme Court.  The prior petition was "relisted" an astonishing 22 times before the Ninth Circuit withdrew its opinion and issued a new one, causing the state to withdraw its petition.  The case was noted many times on this blog, including this post and this post, and it was a "regular" in John Elwood's "Relist Watch" at SCOTUSblog.

The new petition is number 14-191.

News Scan

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Minnesota Inmate Convicted of Murder: A Minnesota inmate has been sentenced to an additional 40 years behind bars after agreeing to plead guilty to killing a fellow inmate last December.  The Associated Press reports that 30-year-old Benjamin Beck plead guilty to second-degree intentional murder after telling prosecutors he had no choice but to kill the other inmate due to the fact that he was a convicted child rapist.  Beck had been incarcerated since 2007 after being convicted of aggravated robbery and first-degree burglary.

Convicted Killer Granted Stay of Execution: An Ohio man sentenced to death after being convicted of killing his two young children and former mother-in-law has been granted a stay of execution.  The Canton Rep reports that James Mammone was scheduled to be executed on March 8, 2017, the stay will remain in effect until he has exhausted all post-conviction court proceedings and appeals.  Mammone recently asked the court reconsider his murder convictions and death sentence, however, the court ruled by a vote of 6-1 to uphold both the verdict and sentence.

CA High Court Upholds Death Sentence: In a unanimous ruling, the California Supreme Court upheld the conviction and death sentence of a man who killed a young woman more than two decades ago.  Marjorie Hernandez of the Ventura County Star reports that Justin Merriman, a documented skinhead gang member, was sentenced to death in 2001 for the rape and murder of a Southern California college student.  Merriman challenged his conviction and sentence based on a claim of juror misconduct and evidence errors.

The Political Uses of Ferguson

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It was to be expected that the Usual Suspects would show up in Ferguson to push the Usual Causes, and would do so without finding out, or having any great interest in finding out, what actually happened.

Was this an NFL-sized gangbanger who had just committed a strong-arm robbery rushing a cop?  Was it a quick-trigger cop who got the drop on a teenager whose main "crime" was walking in the middle of the street?  Was it something else?

We don't know yet, but this fact makes no difference when the main point is to Fire Away.  Thus I bring you this Grievance-on-Steroids piece in the Atlantic.  I never thought I would say this, but it's enough to make Al Sharpton blush.

Nixon in 2016?

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Now here's an intriguing thought. Paul Kane and Robert Costa have this article in the WaPo on the possible impact of the Ferguson debacle on the possible 2016 ambitions of Missouri Governor Jay Nixon.

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