Monday, December 23, 2013

In re Peter Sakarias on Habeas Corpus case brief

In re Peter Sakarias on Habeas Corpus case brief summary
106 P.3d 931 (2005)

Petitioner inmates sought writs of habeas corpus after the court affirmed on automatic appeal their convictions for first degree murder with special circumstances and their death sentences. The court issued orders to show cause on the inmates' claims that the prosecutor, in each trial, had presented factual theories inconsistent with those presented at the co-defendant's trial. The court consolidated the causes, and the referee issued a report.

The inmates broke into the victim's home. When the victim returned home, the inmates immediately attacked her, using a knife and a hatchet. The evidence strongly suggested that the second inmate struck the first, antemortem blow with the hatchet blade, while the first inmate inflicted two post- or perimortem chopping wounds in the bedroom. At each inmate's trial, however, the prosecutor maintained that the inmate on trial had inflicted all of the chopping wounds.


  • The court held that substantial evidence supported the referee's findings that the prosecutor's use of divergent factual theories was intentional and that the prosecutor had strong reason to believe, while prosecuting the first inmate, that the victim was already dead when moved to the bedroom. 
  • The People's bad faith use of inconsistent theories deprived the first inmate of due process, requiring vacation of his death sentence. 
  • Although the first inmate undisputably played a direct role in the brutal, unprovoked killing, other considerations made it impossible for the appellate court to conclude beyond a reasonable doubt that the prosecutorial argument played no role in the penalty decision.

The court granted the first inmate's petition for a writ of habeas corpus insofar as it claimed prosecutorial inconsistency material to the penalty verdict. The court vacated the superior court's judgment insofar as it imposed a sentence of death. The court discharged the order to show cause as to the second inmate's petition.

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