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John Maki

John Maki

Posted: August 20, 2009 07:03 PM

When It Comes to Claims of Actual Innocence, Courts Need to Consider Recantations


On Monday, the U.S Supreme Court ordered a new trial for Troy Davis, a Georgia man who was sentenced to death for the 1989 murder of an off-duty police officer that he said he did not commit.

It was an extraordinary ruling for two reasons. On procedural grounds, the Court rarely hears direct appeals based on a convicted person's claim of actual innocence. But more substantively, the primary evidence of Davis' innocence is that many of the witnesses who testified against him have recanted their original testimony.

You might think that judges would be willing to review convictions based on testimony that was later recanted, but in fact courts frequently ignore recantations when reviewing claims of actual innocence.

Take for example the case of Illinois resident Johnnie Lee Savory, a client of the Center on Wrongful Convictions. In 1981, Savory was convicted of a double homicide and sentenced to 40-80 years in prison based largely on the statements of witnesses who began recanting their testimony almost as soon as his trial was over.

Like many of the witnesses in Davis' case, the witnesses in Savory's case later swore under oath that "their testimony was false," and that they "felt pressure . . . and told [the detective] what he wanted to hear." Despite the recantations in his case, Savory remained in prison until 2006, when he was paroled. Illinois courts have also used this recanted testimony to deny Savory DNA testing that could potentially exonerate him.

Even when courts ultimately allow recanted testimony to exonerate a wrongfully convicted person, the process is often clumsy and contradictory.

In May 2009, for example, Center on Wrongful Convictions' client Thaddeus Jimenez was cleared of all charges stemming from his 1993 murder conviction after several of the original witnesses against him recanted their testimony. Shortly after he was exonerated and released from prison, the real perpetrator was arrested for the crime.

However, if Circuit Court Judge Stanley Sacks had his way, Jimenez would never have been able to use the recantations to prove his innocence. A year before Jimenez was exonerated, Jimenez's lawyers petitioned Judge Sacks for a new trial based on the recantations. Without even granting an oral hearing for Jimenez's lawyers to argue their case, Sacks dismissed the Petition, ruling that the recantations were unlikely to "change the result of this case on retrial" and that the Jimenez's Petition was "frivolous and patently without merit."

As the Davis case shows, there are many judges who think like Judge Sacks, including Supreme Court Justice Antonin Scalia. In his dissent, Scalia dismissed Davis' recantation evidence as "a sure loser." Scalia went so far as to suggest that innocence should be irrelevant when the Supreme Court reviews a death sentence. "This Court," Scalia wrote, "has never held that the Constitution forbids the execution of a convicted defendant who has had a full and fair trial but is later able to convince a . . . court that he is 'actually' innocent."

When it comes to claims of actual innocence, it is to be hoped that courts in Chicago and across the country reject Scalia's approach and embrace the majority's holding in Davis. For every Davis and Jimenez who have been granted an opportunity to use recantations to establish their innocence in court, there are many more people like Johnnie Savory who don't get that chance.

Follow John Maki on Twitter: www.twitter.com/innocencespeaks

On Monday, the U.S Supreme Court ordered a new trial for Troy Davis, a Georgia man who was sentenced to death for the 1989 murder of an off-duty police officer that he said he did not commit. It was ...
On Monday, the U.S Supreme Court ordered a new trial for Troy Davis, a Georgia man who was sentenced to death for the 1989 murder of an off-duty police officer that he said he did not commit. It was ...
 
 
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03:00 PM on 08/21/2009
Nobody here has stated which portion of the US Constitution is violated when a person a court has held is innocent is executed.

That said, my guess is that neither Justice Scalia or anybody else thinks justice is served by such executions. He probably believes that legislative bodies, not the SCOTUS have the job of setting up proper appeals standards and procedures.
02:53 PM on 08/21/2009
Maybe it is true that the US Constitution doesn't forbid the execution of somebody who has convinced a court that he is innocent. The US Constitution is a very short document compared to other constitutions that exist on this planet, e.g. the California or European Union Constitutions. What clause or amendment is it supposed to violate?

However, I doubt that Justice Scalia or anybody else thinks it is good criminal justice to carry out such executions. Maybe he thinks that legislative bodies should set up proper appeal processes and standards.
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rlugbill
02:38 PM on 08/21/2009
My experience is that local court judges are looking at a big caseload and need to process cases. The last thing they want is to retry a case that has already been decided. They want a guilty plea so they can process cases quickly.

There are lots of things that need reforming in our criminal justice system. The conviction of innocent people is one. One thing that contributes to this is that there is little oversight of police officers, district attorneys and judges.

Police do intimidate witnesses and defendants and coerce them into saying what they want them to say. They regularly conceal evidence favorable to defendants. They are biased but pretend to be neutral.

District attorneys and sheriffs (and many judges) are elected and there is political pressure on them to solve cases and convict someone- a rush to judgment, rather than a thorough, reasonable, unbiased investigation. And judges don't want to be seen as unsupportive of law enforcement, so they let the police and DAs get away with things. They don't want to dismiss a case on a "technicality" (as if the U.S. Constitution was a technicality).

Meanwhile, Public Defenders are swamped with excessive caseloads because no one wants to fund lawyers for criminal defendants.

Usually the innocent plead guilty because they don't have any prior convictions so they are offered a good deal with no jail time. That way, there is no risk of losing your job, being away from your family, etc.
01:48 PM on 08/21/2009
I guess its just incomprehensible to me what public policy goal is furthered by continued incarceration or execution of prisoners who are actually innocent but who have exhausted their traditional appeals. Scalia seems to be implying some constitutional value to the "doctrine of finality", that at some point the matter should just be closed, but I have never heard a cogent affirmative rationale other than "the Constitution doesn't specifically say we can't". In my view, this turns the Constitution on its head. I thought that all of the due process protections were designed precisely to promote fairness and prevent miscarriages of justice. To say that you can execute an innocent man because he has had all of his alloted "due process" fundamentally misinterprets the meaning of sufficient due process. By definition, if an innocent man can demonstrate his actual innocence, but some elements of the system want him to continue to suffer undeserved punishment, then I don't think there has been enough due process. Denying people access to a neutral fact finding forum, or technology that could conclusively establish guilt or innocence, appears to be deliberately cruel, malicious and singularly un-American.
01:27 PM on 08/21/2009
Taking part of one paragraph out of a 6 page dissent and trying to say the man is advocating putting to death innocent people is morally bankrupt and intellectually dishonest.

In the name of full disclosure, I am against the death penalty. I would support a federal law banning it. But Scalia is correct on this issue. This is not grounds for a supreme court hearing on this case especially given this same motion had been rejected several times on the state level.

I am curious as to why Mr Maki makes no reference to page 5 of the dissent where Justice Scalia writes:
"When Davis sought clemency before the Georgia Board of Pardons and Paroles, that tribunal stayed his executionand “spent more than a year studying and considering [his] case.” It “gave Davis’ attorneys anopportunity to present every witness they desired to sup-port their allegation that there is doubt as to Davis’ guilt”;it “heard each of these witnesses and questioned them closely.” It “studied the voluminous trial tran-script, the police investigation report and the initial statements of the witnesses,” and “had certain physical evidence retested and Davis interviewed.” “After an exhaustive review of all available information regarding the Troy Davis case and after considering all possible reasons for granting clemency, the Board . . . determinedthat clemency is not warranted.”
12:13 PM on 08/21/2009
As a recent law graduate yourself, you knew this.
12:09 PM on 08/21/2009
I think this piece, particularly with respect to Justice Scalia, is a mis-characterization at best; to suggest, that is, that Scalia cares not for the "innocence" of a man when reviewing his death sentence. “Actual Innocence” is a defense, not Scalia’s personal opinion, that arguably shifts the burden to the defendant to allege as an aegis against the prosecution’s case-in-chief. What Scalia is saying, essentially, is that Davis exhausted so many different avenues that a petition to the Supreme Court must be done through an appropriate and precedent-based channel under federal law. There is no channel here. Since Davis already went to the Georgia Supreme Court, the United States Supreme Court can only hear/overturn their finding of his “Actual Innocence”-defense if federal law allows it/there exists a violation of that law. To say “[t]his Court has never held that the Constitution forbids the execution of a convicted defendant who has had a full and fair trial but is later able to convince a habeas court that he is “actually” innocent” is to say this Court lacks authority, not “kill kill kill the black man”.
This post was wholly misleading, particularly the suggestion Justice Scalia doesn’t care about guilt or innocence. Context and an appreciation for legality is unfortunately missing.
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John Maki
11:24 AM on 08/21/2009
General comment: Thanks for checking out this piece. While Scalia's comment is naturally getting a lot of attention, I think what's in many ways more troubling are state and local judges who probably share his attitude. It's at the state and local level where most cases of actual innocence are heard and never heard from again. Davis' case was heard and dismissed by dozens of Georgia judges and officials, just like Johnnie Savory's case. That's why it's important to support the work of places like the Center on Wrongful Convictions. They're fighting the battle on the front lines.
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LLeGrande
An Increasingly Disgusted Liberal Democrat.
01:51 PM on 08/21/2009
The United States Judicial Branch - at all levels from the Supreme Court to the local courts at the state and county level - is all about procedures, procedures, procedures. These are the top three priorities of the judicial branch.

There is no question in my mind that innocent people have been executed. And, after the execution, files, evidence, etc. is destroyed forever precluding the possibility, sometime in the future when technology allows it, to prove that an innocent person was executed.

Justice Scalia shows clearly what the Judicial Branch is all about: if you follow procedures, then this is the outcome, and it can not be appealed.

This is the same judicial branch which now has one-in-ten Americans behind bars; the one in which the United States' 5% of the world population has 25% of the world's prisoners.

It is a very brutal branch when compared almost everywhere else in the world. We lock 'em up, we punish, we do NOT rehabilitate. We are a very cruel country with a very brutal judicial branch.
10:12 AM on 08/21/2009
Recanted testimony is devalued because if parties to the trial lied in the first place who's to say that they aren't lying in the second place. An oath to tell the whole truth should mean something.

Nonetheless, to use original testimony, later recanted, as a rationale for denying a scientifically objective test that was unavailable at the time of trial is wrong.

I don't want to judge Scalia's points from excerpts, but if unmitigated by context, I think Scalia argues a point that leads to an absurdity. For instance, I don't think the Constitution says any thing explicit about embezzlement or bribes. Does that mean it's okay when done by one of the federal office holders?

Does he really think that a judge, a prosecutor, some more or less competent defense, and twelve peers equal infallibility? Does he think that's what the founding fathers were thinking? I am not as learned man as Justice Scalia, but it seems to me the Constitution is organized under a key premise, that man is fallible.

So we should address the question of miscarriages in justice, not because the Constitution tells us so, but because common sense and humbleness tells us so. In a capital case, in which the state takes away the third of the inalienable three (life, liberty, and the pursuit of happiness), the concern for correctness, for propriety, for justice should be foremost.
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John Maki
11:01 AM on 08/21/2009
Thanks for your comment. I agree with your points, particularly in your last paragraph.
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Scoppertop
Sunny Side
09:31 AM on 08/21/2009
The court system in this country has become just as corrupted, capitalistic, and money-motivated as any other big business. There is no justice to be had, unless one can spend the big bucks on lawyers. An individual can no longer represent themselves fairly and be treated with respect. Our system is altogether broken.
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momcat4obama
02:10 AM on 08/21/2009
It is absolutely unfathomable to me that Justice Scalia actually believes what he said: that the US Constitution does not forbid the execution of one who has had a "full & fair trial" but is later able to "convince" a court that he is innocent!!!! Maybe I am looking at this in too simplistic of a view, but it would seem to me that the idea that a trial is "full & fair" when the testimony against the defendant is proven or admitted to be false, is an oxymoron of the Nth degree! This "argument" of Scalia's should be on the front page of every legal journal and REAL newspaper in the US, if not the world, and he should be forced to explain himself - and he should not be allowed to get away with one of his smart-a$$, condescending comments about the lack of his questioner's intellectual capacity to understand his superior reasoning.