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Lydell Chestnut, Deputy Warden v. Quincy J. Allen

Paid petition · United States Court of Appeals for the Fourth Circuit, No. 20-6 · judgment July 26, 2022


Certiorari denied · May 22, 2023
Pre-decision estimate: 5% cert probability

Before the decision, roughly the 4.1% base rate. The model weighted this up for a state or local-government petitioner, a dissent in the court below (flagged in the petition), and counsel who has filed here before.

Question presented

In February 2005, Respondent Quincy J. Allen pled guilty to two murders in South Carolina. The following month a bench trial for capital sentencing began and spanned 10 days. Allen presented mental health evidence that included a diagnosis of schizophrenia and an eating disorder by history. Allen’s counsel argued the judge should consider that Allen was mentally ill at the time of the crime and less culpable. South Carolina does not require reported findings for statutory or non-statutory mitigation. But, during sentencing, the judge confirmed that he had considered the mental health evidence – the testimony and reports – and even named the experts. The judge sentenced Allen to death. Allen’s sentence withstood detailed review until a divided panel of the Fourth Circuit found in 2022 that, though the sentencing judge mentioned the schizophrenia evidence, he failed to mention the eating disorder; thus, he failed to give “meaningful consideration and effect” to Allen’s evidence and it was unreasonable for the state post-conviction court to find otherwise. The question presented is: Did the Fourth Circuit violate 28 U.S.C. § 2254(d) limitations and needlessly overturn a state death sentence on an insubstantial premise that Allen’s mental health evidence was not afforded “meaningful consideration and effect” when the judge stated at sentencing that he had considered all the mental health evidence but did not explicitly reference Allen’s eating disorder?

Counsel of record

For petitioner
Melody Jane Brown
South Carolina Attorney General's Office

For respondent
Aren Adjoian
Federal Community Defender Office, E.D. Pa.

Case

Conference history
Distributed for 3 conferences

Amicus briefs
1 cert-stage

Proceedings

  1. May 22 2023
    Motion for leave to proceed in forma pauperis filed by respondent GRANTED.
  2. May 22 2023
    Petition DENIED.
  3. May 15 2023
    DISTRIBUTED for Conference of 5/18/2023.
  4. Apr 19 2023
    DISTRIBUTED for Conference of 5/11/2023.
  5. Apr 18 2023
    The record for the U.S.C.A.-4th Circuit is available on PACER.
  6. Apr 18 2023
    Electronic record received from the U.S.D.C.-South Carolina.
  7. Apr 17 2023
    Record Requested.
  8. Apr 13 2023
    Reply of petitioner Lydell Chestnut filed. (Distributed)
  9. Apr 12 2023
    DISTRIBUTED for Conference of 4/28/2023.
  10. Mar 24 2023
    Brief of respondent Quincy Allen in opposition filed.
  11. Mar 24 2023
    Motion for leave to proceed in forma pauperis filed by respondent Quincy Allen.
  12. Feb 24 2023
    Motion to extend the time to file a response is granted and the time is further extended to and including March 24, 2023.
  13. Feb 22 2023
    Motion to extend the time to file a response from February 22, 2023 to March 24, 2023, submitted to The Clerk.
  14. Jan 19 2023
    Motion to extend the time to file a response is granted and the time is further extended to and including February 22, 2023.
  15. Jan 18 2023
    Motion to extend the time to file a response from January 23, 2023 to February 22, 2023, submitted to The Clerk.
  16. Dec 22 2022
    Motion to extend the time to file a response is granted and the time is extended to and including January 23, 2023.
  17. Dec 21 2022
    Motion to extend the time to file a response from December 23, 2022 to January 23, 2023, submitted to The Clerk.
  18. Dec 21 2022
    Brief amicus curiae of Criminal Justice Legal Foundation filed.
  19. Nov 21 2022
    Petition for a writ of certiorari filed. (Response due December 23, 2022)