Facts of the case
Jose Medellin, a Mexican national, was convicted and sentenced to death for participating in the gang rape and murder of two teenage girls in Houston. Medellin raised a post-conviction challenge arguing that the state had violated his rights under the Vienna Convention, a treaty to which the United States is a party. Article 36 of the Vienna Convention gives any foreign national detained for a crime the right to contact his consulate. After his petition was ultimately dismissed by the Supreme Court (see Medellin v. Dretke ), Medellin’s case returned to the Texas Court of Criminal Appeals. Medellin’s argument rested in part on a ruling of the International Court of Justice (ICJ) holding that the U.S. had violated the Vienna Convention rights of 51 Mexican nationals (including Medellin) and that their convictions must be reconsidered. Medellin argued that the Vienna Convention granted him an individual right that state courts must respect, a possibility left open by the Supreme Court’s 2006 decision in Sanchez-Llamas v. Oregon . Medellin also cited a memorandum from the President of the United States that instructed state courts to comply with the ICJ’s rulings by rehearing the cases. Medellin argued that the Constitution gives the President broad power to ensure that treaties are enforced, and that this power extends to the treatment of treaties in state court proceedings.The Texas Court of Criminal Appeals rejected each of Medellin’s arguments and dismissed his petition. The court interpreted Sanchez-Llamas as standing for the principle that rulings of the ICJ are not binding on state courts. The Texas court stood by its position that allowing Medellin to raise the Vienna Convention issue after his trial would violate state procedural rules, and that those rules were not supplanted by the Convention. The President had no authority to order the enforcement in state court of an ICJ ruling, because that would imply a law-making power not allocated to him by the Constitution.
Why is the case important?
Jose Medellin (D) appealed after Texas (P) convicted him of rape and murder on the ground that the plaintiff failed to inform him of his right to have consular personnel notified of his detention by the state as it was required under the Vienna Convention. During his appeal at the Supreme Court, Medellin (D) argued that a case decided by the international Court of Justice suggested that his conviction must be reconsidered to comply with the Vienna Convention.
Are state courts required under the U.S. Constitution to honor a treaty obligation of the United States by enforcing a decision of the International Court of Justice?
(2) Are states courts required by the U.S. Constitution to provide review and reconsideration of a conviction without regard to state procedural default rules as required by a memorandum by the President?
(Roberts, C.J). (1). No. States courts are not required under the U.S. Constitution to honor a treaty obligation of the United States by enforcing a decision of the International Court of Justice. What the Vienna Convention stipulate is that if a person detained by a foreign country asks, the authorities of the detaining national must, without delay, inform the consular post of the detainee of the detention.
(2). State courts are not required by the U.S. Constitution to provide review and reconsideration of a conviction without regard to state procedural default rules as required by a Memorandum by the President. The presidential memorandum was an attempt by the Executive Branch to enforce a non-self-executing treaty without the necessary congressional action, giving it no binding authority on state courts.
The Supreme Court held that neither the ICJ decision nor the President’s memorandum constituted directly enforceable federal law that would preempt state limitations on the filing of successive habeas petitions. The pertinent international agreements, including the Optional Protocol Concerning the Compulsory Settlement of Disputes to the Vienna Convention, Apr. 24, 1963, 21 U.S.T. 325, T.I.A.S. No. 6820 and the United Nations Charter, did not provide for direct enforcement of ICJ judgments. Nor could the President unilaterally execute a non-self-executing treaty by giving it domestic effect, as the power to implement such a treaty fell to Congress.
- Advocates: Donald Francis Donovan on behalf of the Petitioner Paul D. Clement on behalf of the United States as amicus curiae supporting the Petitioner R. Ted Cruz on behalf of the Respondent
- Petitioner: Jose Ernesto Medellin
- Respondent: State of Texas
- DECIDED BY:Roberts Court
- Location: –
|Citation:||552 US 491 (2008)|
|Granted:||Apr 30, 2007|
|Argued:||Oct 10, 2007|
|Decided:||Mar 25, 2008|