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Medellin v. Texas

Supreme Court of the United States

October 10, 2007, Argued; March 25, 2008, Decided

No. 06-984

Opinion

 [*497]  [**1352]  Chief Justice Roberts delivered the opinion of the Court.

The International Court of Justice (ICJ), located in the Hague, is a tribunal established pursuant to the United Nations Charter to adjudicate disputes between member states. In the Case Concerning Avena and Other Mexican Nationals (Mex. v. U.S.), 2004 I. C. J. 12 (Judgment of Mar. 31) (Avena), that tribunal considered a claim brought by Mexico against the United States. The ICJ held that, based on violations of the Vienna Convention, 51 named Mexican nationals [*498]  were entitled to review and reconsideration of their state-court convictions and sentences in the United States. This was so regardless of any forfeiture of the right to raise Vienna Convention claims because of a failure to comply with generally applicable state rules governing challenges to criminal convictions.

In Sanchez-Llamas v. Oregon, 548 U.S. 331, 126 S. Ct. 2669, 165 L. Ed. 2d 557 (2006)  [****14] --issued after Avena but involving [**1353]  individuals who were not named in the Avena judgment--we held that, contrary to the ICJ's determination, the Vienna Convention did not preclude the application of state default rules. After the Avena decision, President George W. Bush determined, through a Memorandum for the Attorney General (Feb. 28, 2005), App. to Pet. for Cert. 187a (Memorandum or President's Memorandum), that the United States would "discharge its international obligations" under Avena "by having State courts give effect to the decision."

Petitioner Jose Ernesto Medellin, who had been convicted and sentenced in Texas state court for murder, is one of the 51 Mexican nationals named in the Avena decision. Relying on the ICJ's decision and the President's Memorandum, Medellin filed an application for a writ of habeas corpus in state court. The Texas Court of Criminal Appeals dismissed Medellin's application as an abuse of the writ under state law, given Medellin's failure to raise his Vienna Convention claim in a timely manner under state law. We granted certiorari to decide two questions. First, is the ICJ's judgment in Avena directly enforceable as domestic law in a state court  [****15] in the United States? Second, does the President's Memorandum independently require the States to provide review and reconsideration of the claims of the 51 Mexican nationals named in Avena without regard to state procedural default rules? We conclude that neither Avena nor the President's Memorandum constitutes directly enforceable federal law that pre-empts state limitations on the  [*499]  filing of successive habeas petitions. We therefore affirm the decision below.

 [***207] I

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552 U.S. 491 *; 128 S. Ct. 1346 **; 170 L. Ed. 2d 190 ***; 2008 U.S. LEXIS 2912 ****; 76 U.S.L.W. 4143; 2008-1 U.S. Tax Cas. (CCH) P50,242; 21 Fla. L. Weekly Fed. S 126

JOSE ERNESTO MEDELLIN, Petitioner v. TEXAS

Subsequent History: Writ of habeas corpus dismissed, Motion denied by, Stay denied by Ex parte Medellin, 280 S.W.3d 854, 2008 Tex. Crim. App. LEXIS 851 (Tex. Crim. App., July 31, 2008)

Stay denied by, Writ of habeas corpus denied Medellin v. Texas, 554 U.S. 759, 129 S. Ct. 360, 171 L. Ed. 2d 833, 2008 U.S. LEXIS 5362 (U.S., Aug. 5, 2008)

Prior History:  [****1] ON WRIT OF CERTIORARI TO THE COURT OF CRIMINAL APPEALS OF TEXAS.

Ex parte Medellin, 223 S.W.3d 315, 2006 Tex. Crim. App. LEXIS 2236 (Tex. Crim. App., 2006)

Disposition: 223 S. W. 3d 315, Affirmed.

CORE TERMS

treaty, Convention, self-executing, binding, judgments, domestic, courts, domestic law, rights, treaty provision, Charter, cases, ratified, parties, obligations, disputes, non-self-executing, provisions, Memorandum, automatically, consular, federal law, tribunal, Commerce, international court of justice, state law, signatory, undertakes, Curiae, Navigation

International Law, Individuals & Sovereign States, General Overview, Treaty Interpretation, Particular Treaties, Dispute Resolution, Tribunals, Governments, Legislation, Interpretation, Intent, History & Practical Construction, Plain Language, Constitutional Law, The Presidency, Foreign Affairs, Congressional Duties & Powers, Criminal Law & Procedure, Order & Timing of Petitions, Procedural Default, Postconviction Proceedings, Courts, Authority to Adjudicate, Remedies, Treaty Formation, Treaty Negotiations, Separation of Powers, Treaty Ratifications, The Judiciary, Sources of International Law, Civil Procedure, Injunctions, Bill of Rights, Delegation of Authority, Police Powers, State & Territorial Governments, Relations With Governments