Medellin v. Texas
United States Supreme Court
128 S.Ct. 1346 (2008)
Jose Medellin (defendant) was sentenced to death for murder in Texas (plaintiff). Medellin appealed, and the judgment was affirmed. The United States was then a party to the Vienna Convention on Consular Relations (Convention) and the Optional Protocol Concerning the Compulsory Settlement of Disputes to the Vienna Convention (Protocol). The Convention gives accused foreign nationals in the United States the right to contact their consulates. The Protocol gives jurisdiction over disputes about the Convention to the International Court of Justice (ICJ). Medellin petitioned a Texas court for habeas corpus on the ground that he was never notified of his rights under the Convention. The court denied the writ, asserting that Medellin’s claim was procedurally barred for failure to raise it in earlier appeals and concluding that the Convention violations had no effect on the outcome. The Texas Court of Appeals affirmed. Medellin petitioned for habeas corpus in federal court, which held that the claim was procedurally barred and concluded no prejudice had occurred. Medellin applied for certification to appeal to the circuit court. The ICJ then ruled in the Case Concerning Avena and Other Mexican Nationals, 2004 I.C.J. 12 (Judgment of Mar. 31) (Avena), that fifty-one Mexican nationals, including Medellin, were entitled to have their convictions reviewed due to Convention violations, regardless of state procedural default rules. The circuit court refused to allow Medellin’s appeal, concluding that the Convention did not confer individual rights and reaffirming that procedural default rules applied to Convention claims. Medellin petitioned the United States Supreme Court for certiorari, which was granted. President George W. Bush then issued a memorandum stating that the United States would comply with its obligations under Avena by having “[s]tate courts give effect to the decision.” Based on this, Medellin again petitioned for habeas corpus in state court. The United States Supreme Court dismissed the petition for certiorari as premature. The Texas court denied Medellin’s petition, and the appellate court concluded that neither Avena nor the president’s memorandum was binding. Medellin petitioned the United States Supreme Court for certiorari, which was granted.
Rule of Law
Holding and Reasoning (Roberts, C.J.)
Concurrence (Stevens, J.)
Dissent (Breyer, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 170,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 13,800 briefs, keyed to 187 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.