On Wednesday, August 7, 2024, Bloomberg Law reported that the Sixth Circuit Court of Appeals affirmed a lower court’s ruling that a death row inmate was entitled to relief from his death sentence due to judicial bias and misconduct during his sentencing proceedings.
The case involved Nathaniel Jackson, who had been convicted of aggravated murder and other charges in Ohio for conspiring to murder his girlfriend’s former husband. He was initially sentenced to death by Judge John M. Stuard. However, the Ohio Supreme Court later found that Stuard had inappropriately engaged in ex parte communications with prosecutors during sentencing and ordered a new sentence be handed down.
At the resentencing, Stuard refused to recuse himself from the case despite having been reprimanded. He also barred Jackson from presenting any new mitigating evidence. Stuard proceeded to resentence Jackson to death using an opinion virtually identical to his original decision.
Jackson appealed, arguing that Stuard was unconstitutionally biased against him and that he had been denied the chance to present relevant mitigating factors as is required by the Supreme Court. On review, the Sixth Circuit agreed with both of Jackson’s arguments. The court found Stuard’s actions, including soliciting the initial prosecution opinion and failing to accept responsibility for his improper conduct, showed a “deep-seated favoritism” for prosecutors that made a fair judgment impossible.
Additionally, the Sixth Circuit ruled that Ohio’s judicial standard requiring a demonstration of a judge’s actual bias and ill will was too strict and contradicted clearly established federal law. At the federal level, it is enough if bias creates an objectively intolerable potential for prejudice against the defendant. Based on the circumstances, the Sixth Circuit concluded Stuard’s decision-making posed at least a significant risk of bias against Jackson.
Due to these severe flaws in Jackson’s sentencing proceedings, the Sixth Circuit affirmed the lower court’s decision granting Jackson relief from his death sentence. The case was described as exemplifying an “extreme judicial malfunction.” It remains to be seen whether Jackson will be resentenced by an impartial judge or face a different outcome.
Source: Bloomberg Law
