In Glossip v. Oklahoma, 604 U.S. ____ (2025), the U.S. Supreme Court docket granted dying row inmate Richard Glossip a brand new trial. The Court docket dominated {that a} new trial was warranted as a result of prosecutors violated their obligation to right false testimony, and that the jury may not have sentenced Glossip to dying if the testimony was corrected.
Details of the Case
In 1997, Justin Sneed beat Barry Van Treese to dying with a baseball bat at an Oklahoma resort owned by Van Treese and managed by petitioner Richard Glossip. Glossip initially made inconsistent statements to the police about Sneed’s function within the homicide, however he finally instructed police that Sneed admitted to killing Van Treese.
Sneed later claimed Glossip had requested him to homicide Van Treese as a result of, amongst different issues, Glossip had needed to steal Van Treese’s cash. Glossip maintained his innocence and refused a plea deal that might have had him keep away from the dying penalty in return for testifying towards Sneed. Sneed then testified towards Glossip at trial in trade for avoiding the dying penalty, and Sneed’s testimony was the one direct proof connecting Glossip to the homicide.
The jury convicted Glossip and sentenced him to dying. The Oklahoma Court docket of Felony Appeals (OCCA) overturned that conviction as a result of the protection had been ineffective in difficult Sneed’s testimony and the rest of the proof solely weakly corroborated Sneed’s account.
On the retrial, Sneed offered inconsistent testimony on potential motives for Glossip’s homicide. Sneed additionally denied that he had been prescribed lithium or seen a psychiatrist. After the protection established (via the State’s health worker) that Van Treese had been attacked with a knife in addition to a bat, Sneed testified that he had repeatedly tried to stab Van Treese within the chest with a pocket knife. However Sneed had beforehand denied stabbing Van Treese each when questioned by the police in addition to at Glossip’s first trial.
Glossip moved for a mistrial primarily based on the prosecution’s failure to inform the protection about Sneed’s change in testimony, which the trial courtroom denied after the prosecution disclaimed any data concerning the change. Glossip was once more convicted and sentenced to dying, and a carefully divided OCCA affirmed, holding that circumstantial proof suggesting Glossip had mismanaged the resort, mixed with Glossip’s concession that he had been dishonest in his preliminary statements after the homicide, sufficiently corroborated Sneed’s testimony that he killed Van Treese at Glossip’s course.
Glossip subsequently filed a number of unsuccessful habeas petitions. Issues over the integrity of his conviction led a bipartisan group of Oklahoma legislators to fee an unbiased investigation by a legislation agency, Reed Smith. In June 2022, Reed Smith reported “grave doubt” about Glossip’s conviction, citing components such because the prosecution’s deliberate destruction of key proof and the false portrayal of Justin Sneed as a non-violent “puppet.”
The State then disclosed seven bins of beforehand withheld paperwork, together with letters suggesting Sneed had thought-about recanting and a notice from prosecutor Connie Smothermon to Sneed’s lawyer noting they need to “get to” Sneed to debate his problematic testimony a couple of knife present in Van Treese’s room.
Glossip filed for post-conviction aid primarily based on this proof and proof revealed by Reed Smith. Glossip additionally argued that, throughout his second trial, Smothermon had interfered with Sneed’s testimony concerning the knife in violation of the rule of sequestration, which prohibits witnesses from listening to one another’s testimony. Oklahoma waived any procedural defenses to Glossip’s claims, and requested the OCCA to disclaim the claims on their deserves. The OCCA denied Glossip’s claims as procedurally barred and meritless.
The State then found extra paperwork revealing that Sneed had been identified with bipolar dysfunction and prescribed lithium, contradicting his trial testimony. The legal professional common decided that Smothermon had knowingly elicited false testimony from
Sneed and did not right it, violating Napue v. Illinois, 360 U.S. 264 (1959), which held that prosecutors have a constitutional obligation to right false testimony.
Glossip filed a successive petition for post-conviction aid, which the legal professional common supported, conceding a number of errors that warranted a brand new trial. The OCCA denied the unopposed petition with no listening to, holding that Glossip’s claims had been procedurally barred below Oklahoma’s Put up-Conviction Procedures Act (PCPA), and additional that the State’s concession was not “primarily based in legislation or truth” as a result of it didn’t create a Napue error.
Supreme Court docket’s Resolution
The Supreme Court docket reversed, holding that the prosecution violated its constitutional obligation to right false testimony below Napue. “As a result of the prosecution violated its obligations below Napue, we reverse the judgment under and remand the case for a brand new trial,” Justice Sonia Sotomayor wrote on behalf of the bulk.
The Supreme Court docket first addressed whether or not the Court docket had the ability to overview Glossip’s case. As Justice Sotomayor defined, the Supreme Court docket is not going to take up a query of federal legislation introduced in a case “if the choice of [the state] courtroom rests on a state legislation floor that’s unbiased of the federal query and sufficient to help the judgment.” A state floor of resolution is unbiased solely when it doesn’t rely upon a federal holding, Foster v. Chatman, 578 U.S. 488, 498 (2016), and likewise shouldn’t be intertwined with questions of federal legislation.
On this case, the Court docket rejected the argument that the Court docket lacked jurisdiction as a result of the OCCA held that Glossip’s claims had been barred below the PCPA, and the PCPA is “a paradigmatic unbiased and sufficient state-law floor.” Justice Sotomayor wrote:
That argument fails as a result of it overlooks an antecedent holding that turned on federal legislation. The OCCA first rejected the legal professional common’s confession of Napue error, deeming it meritless and due to this fact incapable of “overcom[ing]” software of the PCPA. Solely then did it apply the PCPA to Glossip. As a result of the OCCA’s resolution to reject the legal professional common’s confession of error rested completely on federal legislation, so too did its subsequent resolution to use the PCPA.
The Court docket subsequent decided that prosecutors “violated [their] constitutional obligation to right false testimony” below Napue. To determine a Napue violation, a defendant should present that the prosecution knowingly solicited false testimony or knowingly allowed it “to go uncorrected when it seem[ed].” If the defendant makes that exhibiting, a brand new trial is warranted as long as the false testimony “might have had an impact on the result of the trial,”— that’s, if it “in any cheap chance [could] have affected the judgment of the jury. ”
On this case, the bulk discovered {that a} materials violation occurred, which warranted a brand new trial. As Justice Sotomayor famous, the proof confirmed that Sneed was prescribed lithium to deal with bipolar dysfunction, not after asking for chilly medication as he claimed at trial. The proof additionally revealed that the prosecution knew Sneed’s testimony was false, because the prosecution virtually actually had entry to Sneed’s medical file via Sneed’s competency analysis.
The bulk additionally discovered that as a result of Sneed’s testimony was the one direct proof of Glossip’s guilt, the jury’s evaluation of Sneed’s credibility was materials and essentially determinative. Justice Sotomayor wrote:
Had the prosecution corrected Sneed on the stand, his credibility plainly would have suffered. That correction would have revealed to the jury not simply that Sneed was untrustworthy (as amicus factors out, the jury already knew he repeatedly lied to the police), but additionally that Sneed was keen to misinform them below oath. Such a revelation could be vital in any case, and was particularly so right here the place Sneed was already “no one’s concept of a powerful witness.”
Even when Sneed’s bipolar dysfunction had been wholly irrelevant, as amicus argues, his willingness to lie about it to the jury was not.
The Supreme Court docket additional that OCCA misinterpreted Napue, noting that whereas it held that there was no violation as a result of the protection was conscious or ought to have been conscious that Sneed was taking lithium, Sneed’s false testimony involved the explanations for his prescription, not merely the truth that he had taken lithium. Furthermore, the Due Course of Clause imposes the responsibility to right false testimony on the State, not the protection.
Justices Clarence Thomas and Samuel Alito dissented, arguing that the Court docket ought to have upheld Glossip’s conviction and dying sentence. Justice Amy Coney Barrett filed an opinion concurring partly and dissenting partly. She would have allowed a state appeals courtroom to resolve proceed somewhat than order a brand new trial. Justice Neil Gorsuch didn’t take part within the case.
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