Williams v. Taylor

Facts

James dropped off P and his friend Cruse near a local store in a rural area of Virginia. The pair planned to rob the store's employees and customers using a .357 revolver P had stolen in the course of a quadruple murder and robbery he had committed two months earlier. The store was closed. P and Cruse walked to the Kellers' home. P was familiar with the couple. P told Cruse they would have 'a couple thousand dollars.' Cruse handed the gun to P and knocked on the door. When Mr. Keller opened the door, P pointed the gun at him as the two forced their way inside. Cruse forced Mr. Keller to the kitchen and discovered Mrs. Keller. P ordered the captives to remove their clothing. Cruse searched the house for money and other valuables. He found a .38-caliber handgun and bullets. P had Cruse tie their captives with telephone cords. The Kellers were confined to separate closets while the intruders continued ransacking the house. P and Cruse decided to rape Mrs. Keller. P raped her. Cruse did the same. P ordered the Cruses to shower and dress and 'take a walk.' P told Mrs. Keller he and Cruse were going to burn down the house. Mrs. Keller begged to be allowed to retrieve her marriage license, which she did, guarded by P. P with the .38, and Cruse with the .357, took the Kellers to a thicket down a dirt road. P shot Mr. Keller in the head, and Mr. Keller collapsed to the ground. Cruse did not shoot Mrs. Keller at the same moment. P urged Cruse to shoot Mrs. Keller. Cruse fired one shot into her head. Despite his wound, Mr. Keller stood up, and P shot him a second time. P shot each of them two or three more times. P and Cruse torched the house and went to Fredericksburg and sold some of the property, three what remanded the .357 into the Rappahannock River and set fire to the Jeep they had used. Pursuing a lead from James, the police interviewed Cruse about the fire. P had fled to Florida. Cruse provided no useful information. The police discovered the bodies and in a plea bargain, Cruse agreed to disclose the details of the crimes in exchange for the Commonwealth's promise not to seek the death penalty against him. Cruse spilled everything but left out the rape. The Commonwealth revoked his plea agreement and charged him with capital murder. P was arrested and charged. Cruse was the Commonwealth's main witness. P admitted he was the first to shoot Mr. Keller and it was his idea to rob the store and set fire to the house. He denied raping or shooting Mrs. Keller and claimed to have shot Mr. Keller only once. P blamed Cruse for the remaining shots and disputed some other parts of Cruse's testimony. D was convicted and sentenced to death. The Supreme Court of Virginia affirmed. Cruse was sentenced to life. P filed a habeas petition in state court alleging that the Commonwealth failed to disclose a second plea agreement it had reached with Cruse. The Virginia Supreme Court dismissed the habeas petition. P filed a habeas petition in the District Court. P pled the undisclosed agreement between the Commonwealth and Cruse, the prosecution had violated Brady v. Maryland, P's trial was rendered unfair by the seating of a juror who at voir dire had not revealed possible sources of bias, and one of the prosecutors committed misconduct in failing to reveal his knowledge of the juror's possible bias. The District Court granted an evidentiary hearing on the undisclosed agreement and the allegations of juror bias and prosecutorial misconduct but denied a hearing on the psychiatric report. The Commonwealth filed an application for an emergency stay and a petition for a writ of mandamus and prohibition in the Court of Appeals. The Court of Appeals granted the emergency stay and remanded for the District Court to apply the statute to P’s request for an evidentiary hearing. On remand, the District Court vacated its order granting an evidentiary hearing and dismissed the petition, having determined petitioner could not satisfy § 2254(e)(2)'s requirements. The Court of Appeals affirmed. The court held, however, that P had not been diligent and so had 'failed to develop' in state court the factual bases of his Brady, juror bias, and prosecutorial misconduct claims. It then found that P could not satisfy the statute's conditions for excusing his failure to develop the facts and held him barred from receiving an evidentiary hearing. P filed an application for a stay of execution and a petition for a writ of certiorari. The Commonwealth argues AEDPA bars P from receiving an evidentiary hearing on any claim whose factual basis was not developed in state court. P claims he was unaware, through no fault of his own, of the underlying facts. As a consequence, P contends, AEDPA erects no barrier to an evidentiary hearing in federal court.

Issues

Rule of Law

Holding and Decision

Legal Analysis

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