Styers v. Ryan, No. 12-16952 [December 30, 2015]
Styers first habeas petition was granted based on Arizona’s erroneous application of its “casual nexus” requirement for mitigating evidence. On remand, the Arizona Supreme Court independently reviewed his death sentence and again affirmed it. Styers now claims that the Arizona Supreme Court could not correct the error and that a death sentence could now only be imposed by a jury’s determination of the aggravating factors that rendered him eligible for the death Penalty in light of Ring v. Arizona. The Arizona Supreme Court denied his claim on the ground that his conviction was final and, therefore, he was not entitled to a Ring sentencing. The court held that because the U.S. Supreme Court has never held that the issuance of a conditional writ of habeas corpus necessarily renders non-final a conviction or sentence that was predicated on constitutional error, and the conditional writ of habeas corpus did not vacate Styers’s death sentence that the Arizona Supreme Courts decision was not contrary to federal law as determined by the Supreme Court of the United States. The court also rejected Styers’s argument that Arizona Supreme Court failed to correct its previous error because it treated Stylers’s mitigation evidence as de minimis holding that U.S. Supreme Court law did not require more.