[JURIST] The US Supreme Court [official website] heard oral arguments [day call, PDF] in two cases Tuesday. In Duncan v. Owens [transcript, PDF] the court heard arguments [SCOTUSblog backgrounder] to determine whether habeas relief can be given without precedent that the inference of motive at trial violates the defendant’s right to due process. The case arose [Oyez summary] when Lawrence Owens, who was convicted of first-degree murder and sentenced to 25 years in prison, filed a petition for a writ of habeas corpus on the grounds that his right to due process was violated at trial. He had been convicted of murder with the judge also inferring that Owen was most likely a drug dealer since his victim had drugs on him. Owens argued that the eyewitness identification at trial was inadmissible and that the judge impermissibly inferred motive when a motive was not an element of the offense. The US Court of Appeals for the Seventh Circuit [official website] reversed the district court’s denial of Owens’ writ of habeas corpus, stating that the judge should have adjudicated the case based solely on the evidence presented at trial.
The court also heard arguments in Molina-Martinez v. US [transcript, PDF] on whether [SCOTUSblog backgrounder] when an error in a US Sentencing Guidelines application results in the wrong guideline range given to a defendant, an appellate court should presume that the error affected the defendant’s substantial rights. The case arose [Oyez summary] when Saul Molina-Martinez plead guilty to being in the US illegally after being deported due to felony convictions. The district court sentenced him to 77 months in prison. He alleged that his probation officer calculated his criminal history points wrong and placed him in the wrong sentencing guideline range. The US Court of Appeals for the Fifth Circuit [official website] ruled that despite the error, his substantial rights were not affected and therefore affirmed his conviction and sentence.