Medellin v. Texas

552 U.S. 491 (2008)

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Nature of the Case

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Facts

The International Court of Justice held that, based on violations of the Vienna Convention, 51 named Mexican nationals were entitled to review and reconsideration of their state-court convictions and sentences in the United States. This was so regardless of any forfeiture of the right to raise Vienna Convention claims because of a failure to comply with generally applicable state rules governing challenges to criminal convictions. P, a Mexican national, has lived in the United States since preschool. P was a member of the “Black and Whites” gang and was convicted of capital murder and sentenced to death in Texas for the gang rape and brutal murders of two Houston teenagers. A 14-year-old Jennifer Ertman and 16-year-old Elizabeth Pena were walking home when P and several fellow gang members raped both girls for over an hour. Then, to prevent their victims from identifying them, P and his fellow gang members murdered the girls and discarded their bodies in a wooded area. P was personally responsible for strangling at least one of the girls with her own shoelace. A few hours after arrest P was given Miranda warnings; he then signed a written waiver and gave a detailed written confession. Officers did not inform P of his Vienna Convention right to notify the Mexican consulate of his detention. P was convicted of capital murder and sentenced to death; his conviction and sentence were affirmed on appeal. P first raised his Vienna Convention claim in his first application for state postconviction relief. The court rejected the claim because it was not raised at trial or on direct review. The trial court also rejected the Vienna Convention claim on the merits, finding that Medelln had “fail[ed] to show that any non-notification of the Mexican authorities impacted on the validity of his conviction or punishment.” P then filed a habeas petition in Federal District Court. The District Court denied relief, as the Vienna Convention claim was procedurally defaulted and P had failed to show prejudice arising from the Vienna Convention violation. While awaiting an appeal to the Fifth Circuit, the ICJ held that the United States had violated Article 36(1)(b) of the Vienna Convention by failing to inform the 51 named Mexican nationals, including Medelln, of their Vienna Convention rights. The Fifth Circuit denied a certificate of appealability. The Court granted certiorari. Before oral arguments, President Bush (43) issued his Memorandum and ordered the States courts to give effect to the ICJ decision in accordance with general principles of comity in cases filed by the 51 Mexican nationals addressed in that decision. P then filed a second application for habeas relief in state court and the Supreme Court dismissed his petition for certiorari as improvidently granted. The Texas Court of Criminal Appeals subsequently dismissed P’s second state habeas application as an abuse of the writ. The Court again granted certiorari.