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Constitutional Law Keyed to Stone
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 in 1993. Medellín confessed to the crimes within three hours of his arrest. He was not informed of his right under the Vienna Convention to notify the Mexican consulate of his detention. After his conviction was affirmed and state habeas relief denied, Medellín filed a federal habeas petition raising the Vienna Convention claim for the first time. While his case was pending, Mexico initiated proceedings against the United States in the International Court of Justice (ICJ) on behalf of 51 Mexican nationals, including Medellín, alleging violations of the Vienna Convention. In 2004, the ICJ issued its judgment in Case Concerning Avena and Other Mexican Nationals, holding that the United States had violated the Vienna Convention and ordering “review and reconsideration” of the convictions of the Mexican nationals. President Bush then issued a memorandum stating that the United States would comply with the ICJ’s decision by having state courts give effect to the Avena judgment. Based on this memorandum, Medellín filed a second state habeas application in Texas. The Texas Court of Criminal Appeals dismissed the application, holding that neither the ICJ decision nor the President’s memorandum constituted binding federal law that could override state procedural rules.
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