LOCATION: U.S. Court of Appeals for the Seventh Circuit
DOCKET NO.: 14-1516
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Seventh Circuit
CITATION: 577 US (2016)
GRANTED: Oct 01, 2015
ARGUED: Jan 12, 2016
DECIDED: Jan 20, 2016
Barry Levenstam – for the respondent
Carolyn E. Shapiro – for the petitioner
Facts of the case
Ramon Nelson was riding his bike when he suffered a lethal blow to the back of his head with a baseball bat. After two eyewitnesses identified Lawrence Owens from an array of photos and then a lineup, he was tried and convicted for Nelson’s death. Because Nelson was carrying cocaine and crack cocaine potentially for distribution, the judge at Owens’ bench trial ruled that Owens was probably also a drug dealer and was trying to “knock [Nelson] off.” Owens was found guilty of first-degree murder and sentenced to 25 years in prison.
Owens filed a petition for a writ of habeas corpus on the grounds that his constitutional right to due process was violated during the trial. He argued that the eyewitness identification should have been inadmissible based on unreliability and that the judge impermissibly inferred a motive when a motive was not an element of the offense. The district court denied the writ of habeas corpus, and Owens appealed. The U.S. Court of Appeals for the Seventh Circuit reversed the denial and held that the trial judge’s inference about Owens’s motive violated his right to have his guilt adjudicated solely based on the evidence presented at trial.
Can habeas relief be awarded in the absence of clearly established precedent that the inference of motive at trial violates the defendant’s right to due process?
Media for Duncan v. Owens
Audio Transcription for Opinion Announcement – January 20, 2016 in Duncan v. Owens
John G. Roberts, Jr.:
In case 14-1516, Duncan against Owens, the Writ of Certiorari is dismissed as improvidently granted.