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Name: Bradshaw v. Stumpf
Case #: 04-637
Court: US Supreme Court
District USSup
Opinion Date: 06/13/2005
Subsequent History: x-cite 125 S.Ct. 2398
Summary

Stumpf and Wesley committed a robbery during which Mr. Stout was wounded and Mrs. Stout was killed. Stumpf pleaded guilty to aggravated murder, and following a contested penalty hearing, a three-judge panel sentenced him to death. At Wesley’s subsequent jury trial, the prosecutor argued that Wesley had been the shooter. Wesley argued that the prosecutor had argued a conflicting theory in the Stumpf case, and was sentenced to life in prison. Stumpf moved to withdraw his plea, arguing that the evidence endorsed by the prosecutor in the Wesley trial cast doubt on his own conviction and sentence. The Sixth Circuit granted Stumpf habeas relief, finding that Stumpf had not understood the requirement of specific intent to cause death as a necessary element of aggravated murder charge, and that his plea was not knowing and voluntary. Further, the sentence and conviction could not stand due to the conviction of both Stumpf and Wesley for the same crime, using inconsistent theories. The United States Supreme Court reversed. The Sixth Circuit erred in concluding that Stumpf was uninformed of the specific intent element. Evidence showed that both men had agreed to kill both Stouts, which would make both guilty of aggravated murder (in Ohio) regardless of who shot Mrs. Stout. The plea’s validity cannot be attacked on the ground that Stumpf made what he now considers to be a bad deal. Further, the Sixth Circuit was wrong to hold that prosecutorial inconsistencies between the prosecutions required the voiding of Stumpf’s guilty plea. The identity of the triggerman was immaterial to the conviction, and Stumpf never explained how the use of post-plea inconsistent arguments could have affected the voluntary and knowing nature of his plea. However, the use of inconsistent theories may have had a more direct effect on Stumpf’s sentencing. Since the Sixth Circuit did not have a chance to consider this because it considered the conviction invalid, remand was required to reconsider Stumpf’s death sentence.