Summary
The Eighth Circuit vacated a district court's stay of execution for habeas petitioner Walter Barton, holding that he failed to show a significant possibility of success on the merits. The court found the Missouri Supreme Court's competency determination was not an unreasonable application of *Madison v. Alabama* because Barton's own expert concluded he rationally understood the punishment. Barton's actual innocence gateway claim failed because his evidence regarding witness credibility was not "new" (available at trial) or, for a 2016 conviction, insufficient to show no reasonable juror would have convicted. The court emphasized that under § 2254(d), a state court decision must be both incorrect and unreasonable to warrant relief.
Topics
Practice areas
Questions Presented
- Whether the Missouri Supreme Court unreasonably applied federal law or unreasonably determined facts regarding Barton's competency for execution.
- Whether Barton can raise a gateway actual innocence claim to overcome procedural default.
Holdings
- The Missouri Supreme Court's determination that Barton was competent to be executed was not an unreasonable application of clearly established federal law and not based on an unreasonable determination of the facts.
- Barton cannot satisfy the two-part test for gateway actual innocence because his evidence is not new or is insufficient.
Key quotations
“To prevail, inmates must satisfy all of the requirements for a stay, including a showing of a significant possibility of success on the merits.” (at 2)
“When, as here, an application for a writ of habeas corpus has been adjudicated on the merits in state court, we may grant a writ only where the adjudication: (1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States; or (2) resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.” (at 3)
Factual background
Barton was convicted of first-degree murder. He raised claims of incompetence for execution and actual innocence. The Missouri Supreme Court found him competent and rejected his actual innocence claim. Barton then filed a federal habeas petition and sought a stay of execution.
Procedural history
Barton was convicted of first-degree murder after multiple trials. His conviction was affirmed by the Missouri Supreme Court, and federal habeas relief was denied. He filed a state habeas petition claiming incompetence and actual innocence, which was denied. He then filed a federal habeas petition and motion for stay of execution. The district court granted the stay. The State appeals.
Remand instructions
remand with instructions to dismiss the petition