Michael Martel, Warden, Petitioner v. Kenneth Clair (565 U.S. 648)
U.S. Supreme Court · decided March 5, 2012 · Supreme Court Database (Spaeth)
- Citation
- 565 U.S. 648 · 132 S. Ct. 1276
- Decided
- March 5, 2012
- Term
- October Term 2011
- Vote
- 9–0
- Majority author
- Justice Kagan
- Issue area
- Civil Rights
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice Kagan delivered the opinion of the Court. A federal statute, § 3599 of Title 18, entitles indigent defendants to the appointment of counsel in capital cases, including habeas corpus proceedings. The statute contemplates that appointed counsel may be “replaced . . . upon motion of the defendant,” § 3599(e), but it does not specify the standard that district courts should use in evaluating those motions. We hold that courts should employ the same “interests of justice” standard that they apply in non-capital cases under a related statute, § 3006A of Title 18. We also hold that the District Court here did not abuse its discretion in denying respondent Kenneth Clair’s motion to change counsel. I This case arises from the murder of Linda Rodgers in 1984. Rodgers resided at the home of Kai Henriksen and Margaret Hessling in Santa Ana, California. Clair was a squatter in a vacant house next door. About a week prior to the murder, police officers arrested Clair for burglarizing the Henriksen-Hessling home, relying on information Henriksen had provided. On the night the police released Clair from custody, Hessling returned from an evening out to find Rodgers’ dead body in the master bedroom, naked from the waist down and beaten, stabbed, and strangled. Some jewelry and household items were missing from the house. See People v. Clair, 2 Cal. 4th 629, 644-647, 828 P. 2d 705,…
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