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Medellin v. Texas

United States Supreme Court
128 S.Ct. 1346 (2008)


Facts

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

Issue

Holding and Reasoning (Roberts, C.J.)

Concurrence (Stevens, J.)

Dissent (Breyer, J.)

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