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Constitutional Law Keyed to Choper
Medellín v. Texas
Citation:
552 U.S. 491 (2008)Facts
José Ernesto Medellín, a Mexican national, was convicted of capital murder and sentenced to death in Texas for his participation in the gang rape and murder of two teenage girls. After his conviction, Medellín filed a habeas petition arguing that Texas authorities had failed to notify him of his right to consular assistance under the Vienna Convention on Consular Relations. While his case was pending, the International Court of Justice issued its judgment in Avena, ruling that the United States had violated the Vienna Convention rights of 51 Mexican nationals, including Medellín, and ordering review and reconsideration of their convictions and sentences. President Bush then issued a memorandum directing state courts to give effect to the ICJ’s decision. Despite this, the Texas Court of Criminal Appeals dismissed Medellín’s subsequent habeas application, holding that neither the ICJ decision nor the President’s memorandum constituted binding federal law that could displace state procedural default rules.
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