Teleguz v. Pearson, No. 11-9

Decided: August 2, 2012

On appeal, the Court of Appeals reversed and remanded the district court’s dismissal of Ivan Teleguz’s 28 U.S.C. § 2254 petition for habeas corpus relief.  The Court of Appeals held that the district court abused its discretion in failing to conduct a sound and thorough analysis of Teleguz’s Shclup v. Delo, 513 U.S. 298 (1995), gateway innocence claim.

In February 2006, Ivan Teleguz was convicted of capital murder for hire and sentenced to death after his former girlfriend was found dead in the apartment she shared with his infant son.  Although DNA evidence linked another man to the murder, he testified at trial that he was hired by Teleguz to commit the crime.  Two additional witnesses corroborated this story.  Teleguz’s conviction and sentence were upheld by the Supreme Court of Virginia.  He then filed a petition for writ of habeas corpus in state court, which was dismissed by the Supreme Court of Virginia.  In November 2010, Teleguz filed a petition for writ of habeas corpus in federal court asserting various claims, some of which had been adjudicated on the merits by the Supreme Court of Virginia, and others which had been procedurally defaulted.  The district court denied Teleguz habeas relief and his request for an evidentiary hearing.

Teleguz argued that pursuant to Schlup, the district court should consider the merits of his procedurally defaulted claims because new and reliable evidence established that he was actually innocent of the murder.  In support of this gateway innocence claim, he offered several categories of evidence, most notably that the two corroborating witnesses had recanted their testimony.  If a state court adjudicates a petitioner’s claims on the merits, a federal court may only award habeas relief if the resulting state court decision is contrary to clearly established federal law or is an unreasonably application of clearly established federal law.  In Shlup, the Supreme Court recognized that in certain cases, a compelling showing of actual innocence would enable a federal court to consider the merits of a petitioner’s otherwise defaulted claims.  Although a petitioner claims actual innocence for this purpose, the claim for relief relies critically on the validity of his procedurally defaulted claims.  When reviewing the gateway innocence claim, a district court must consider all of the evidence, old and new, and determine whether it is more likely than not that no reasonable juror would have found the petitioner guilty beyond a reasonable doubt.  If it is more likely than not, the district court must review the petitioner’s procedurally defaulted claims.  Because the district court simply stated that Teleguz had not shown cause and prejudice or a fundamental miscarriage of justice to excuse the default of his claims, a sound analysis was not conducted as required by Schlup.  The Court of Appeals further held that the district court abused its discretion because it based its analysis of Teleguz’s claims on a mistake of law by applying its Schlup analysis to individual procedurally defaulted claims rather than analyzing whether Teleguz had demonstrated that the totality of the evidence would prevent any reasonable juror from finding him guilty beyond a reasonable doubt, such that his incarceration was a miscarriage of justice.  If a petitioner satisfies this standard, the district court then reaches the merits of all of the petitioner’s procedurally defaulted claims.  The Court of Appeals remanded the case with instructions for the district court to specifically address whether Teleguz should be granted an evidentiary hearing on his Schlup gateway innocence claim.

Full Opinion

-Nora Bennani

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