Friday, October 23, 2009

Supreme Court: Appellate Courts Must Give Reasons for Decision

It is always good to be reminded that the force, persuasiveness, and acceptability of an appellate court opinion will depend upon the court giving reasons for its decision. When that reminder comes from the United States Supreme Court it is worth taking note of it.

Earlier this week in Corcoran v. Levenhagen the Supreme Court admonished the United States Court of Appeals for the Seventh Circuit for directing, without explanation, that a petition for a writ of habeas corpus be dismissed.

Corcoran had been convicted of murder in Indiana state court and sentenced to death. In his petition for a writ of corpus filed in the United States District Court he alleged five errors had made the state sentencing proceeding constitutionally defective. The District Judge granted the writ on one of those grounds--his sentence violated the Sixth Amendment--and ordered that he be resentenced to a penalty other than death. The court did not address Corcoran's other claims because they were "rendered moot" by the order that he be resentenced.

On appeal the Seventh Circuit reversed the district court's Sixth Amendment determination, stated Corcoran could be sentenced to death, and did not address his other sentencing claims. Corcoran sought a rehearing on the grounds his other sentencing claims should be addressed. The Seventh Circuit denied a rehearing.

A unanimous Supreme Court vacated the ruling of the Seventh Circuit, concluding it had erred in disposing of Corcoran's other claims "without any explanation of any sort." The district court should have been directed to consider Corcoran's other claims or the Seventh Circuit "should have itself explained why such consideration was unnecessary." The opinion can be found here.

This is an important reminder that appellate rulings cannot engender respect unless courts explain themselves.

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