James Scott v. Ron Broomfield

── James Scott v. Ron Broomfield ── Court: Court of Appeals for the Ninth Circuit Date: April 29, 2026 Category: General FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT JAMES ROBERT SCOTT, No. 22-99000 Petitioner-Appellee, D.C. No. 2:03-cv-00978- v. ODW RONALD BROOMFIELD, Warden, California State Prison at San Quentin, OPINION Respondent-Appellant. Appeal from the United States District Court for the Central District of California Otis D. Wright II, District Judge, Presiding Argued and Submitted March 19, 2025 San Francisco, California Filed April 29, 2026 Before: Jacqueline H. Nguyen, Ryan D. Nelson, and Bridget S. Bade, Circuit Judges. Opinion by Judge Nguyen; Concurrence by Judge R. Nelson 2 SCOTT V. BROOMFIELD SUMMARY* Habeas Corpus / Death Penalty The panel reversed the district court’s grant of habeas corpus relief to James Robert Scott on Scott’s guilt phase ineffective-assistance-of-counsel (IAC) claim, and remanded for consideration of remaining claims, in a case in which a California judge found Scott guilty, following a bench trial, of first degree murder with special circumstances and sentenced him to death. The district court concluded that defense counsel William Clark performed deficiently in numerous ways and these deficiencies cumulatively prejudiced Scott. Applying the deferential standards set forth in the Antiterrorism and Effective Death Penalty Act to the California Supreme Court’s decision denying relief, the panel concluded that Scott’s IAC claim fails. Scott argued that Clark was ineffective in failing to investigate and present a mental state defense. The panel did not need to decide whether Clark’s decisions related to a possible mental defense amounted to deficient performance because the California Supreme Court reasonably concluded that any deficient performance did not result in prejudice. Scott argued that Clark was ineffective in presenting a defense that the victim’s death was not caused by Scott but rather by medical malpractice, a defense Scott asserted was “a non-starter.” The panel held that the California Supreme * This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader.  SCOTT V. BROOMFIELD 3 Court reasonably held that Clark’s choice in relying primarily on medical malpractice as a cause of death was not deficient. Scott argued that Clark misunderstood the law and was ineffective for arguing that Carlos v. Super. Ct., 672 P.2d 862 (Cal. 1983), required premeditation and not just an intent to kill. The panel held that because Clark argued both that Scott lacked intent to kill, in part due to voluntary intoxication, and that Carlos should be interpreted to require more than intent, the California Supreme Court reasonably concluded that Clark’s advocacy on behalf of his client was effective. Scott argued that Clark was ineffective for informing the judge of his prior guilty plea. The panel held that the California Supreme Court reasonably determined that trial counsel made a tactical decision to introduce evidence of Scott’s guilty plea. Scott argued that Clark was ineffective for advising him to waive a jury trial. The panel held that the California Supreme Court’s finding that Clark’s advice was based on “valid tactical reasons” was not unreasonable. Scott argued that Clark was ineffective for failing to move to suppress his confessions on the grounds that his Miranda waiver was invalid and his statements were involuntary. The panel held that Scott failed to show that counsel would have prevailed on a suppression motion on either ground and thus the California Supreme Court could hav