Wynn Satterlee v. Hugh Wolfenbarger
2006 WL 1788981, 453 F.3d 362, 2006 U.S. App. LEXIS 16447 (2006)
Rule of Law:
A federal habeas court may order a prisoner's immediate release and expungement of their conviction record when the state fails to comply with a conditional writ granted due to ineffective assistance of counsel for failing to communicate a favorable plea offer, provided the ineffective assistance claim was properly exhausted in state courts and supported by clear factual findings.
Facts:
- Wynn Satterlee was convicted by a Michigan jury of conspiring to deliver more than 650 grams of cocaine.
- Satterlee was sentenced to twenty to thirty years’ imprisonment for his conviction.
- On the day of Satterlee's trial, the state prosecutor, John Cipriani, made a plea offer to Satterlee's attorney, David Dodge, for Satterlee to plead guilty in exchange for a sentence of six to twenty years.
- David Dodge failed to communicate this six-to-twenty-year plea offer to Wynn Satterlee.
- Satterlee testified that he would have accepted the six-to-twenty-year plea offer had it been communicated to him.
Procedural Posture:
- Wynn Satterlee was convicted by a Michigan jury of conspiring to deliver more than 650 grams of cocaine and sentenced to twenty to thirty years’ imprisonment.
- Satterlee appealed his conviction to the Michigan Court of Appeals, which affirmed the conviction.
- The Michigan Supreme Court denied leave to appeal Satterlee's conviction.
- Satterlee moved for relief from judgment pursuant to Michigan Court Rule 6.502, arguing, among other things, ineffective assistance of counsel for failure to relay a favorable plea offer.
- The state trial court denied Satterlee's motion for relief from judgment.
- Both the Michigan Court of Appeals and the Michigan Supreme Court denied leave to appeal the denial of the motion for relief from judgment.
- Satterlee filed a petition for a writ of habeas corpus in federal district court (E.D. Michigan).
- The district court conducted an evidentiary hearing, found that a plea offer was not communicated, and granted a conditional writ of habeas corpus, ordering the state to reinstate the six-to-twenty-year plea offer within sixty days.
- The State of Michigan appealed the conditional writ to the United States Court of Appeals for the Sixth Circuit (No. 05-2013).
- When the state failed to comply with the conditional writ's sixty-day deadline, Satterlee applied to the district court for immediate release.
- The district court denied the state’s motion for a stay pending appeal and granted Satterlee an unconditional writ, ordering his immediate release and the expungement of his record of conviction.
- The State of Michigan appealed the unconditional writ to the United States Court of Appeals for the Sixth Circuit (No. 05-2513).
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a federal district court have the power to grant an unconditional writ of habeas corpus, ordering immediate release and expungement of a conviction record, when a state fails to comply with a conditional writ mandating the reinstatement of a plea offer that a defendant would have accepted but for ineffective assistance of counsel?
Opinions:
Majority - Karen Nelson Moore
Yes, a federal district court has the power to grant an unconditional writ of habeas corpus, ordering immediate release and expungement of a conviction record, when a state fails to comply with a conditional writ based on ineffective assistance of counsel. The court affirmed the district court's decision in both consolidated appeals. Regarding the conditional writ (No. 05-2013), the court found Satterlee's ineffective assistance of counsel (IAC) claim properly exhausted. Satterlee had 'fairly presented' the substance of his claim, including the factual basis of the 'morning offer' of six to twenty years, to the state courts, consistent with Vasquez v. Hillety, even though earlier filings focused on a 'letter offer.' The court also affirmed the district court's factual findings—that the prosecutor made a six-to-twenty-year plea offer and that Satterlee's attorney, David Dodge, never communicated it—as not clearly erroneous, giving particular deference to the district court's credibility determinations. The court found that the state's arguments regarding Satterlee's alleged inconsistencies were without merit. Given these facts, the state courts' denial of Satterlee's IAC claim was an unreasonable application of Strickland v. Washington and Hill v. Lockhart. Regarding the unconditional writ (No. 05-2513), the court held that immediate release is a mandatory consequence when a state fails to comply with a conditional writ of habeas corpus, citing Fisher v. Rose and Wilkinson v. Dotson. A conditional writ is an accommodation to the state to cure a constitutional error, and non-compliance requires the petitioner's release. Furthermore, the court affirmed the district court's power to order expungement of Satterlee's conviction record. Citing 28 U.S.C. § 2243, which allows courts to 'dispose of the matter as law and justice require,' and Supreme Court precedents like Preiser v. Rodriguez and Carafas v. LaVallee, the court determined that the remedial power of habeas courts is not limited solely to ordering discharge from physical custody and includes expungement. The court did remand the case for the district court to clarify whether its unconditional writ intended to bar reprosecution and to provide justification if so. It also suggested that if reprosecution is permitted, the state should be mandated to reinstate the original plea offer to properly tailor the remedy to the constitutional injury.
Analysis:
This case significantly reinforces the authority of federal habeas courts to enforce conditional writs and provide comprehensive remedies for constitutional violations. By affirming the district court's power to order immediate release and expungement upon a state's non-compliance, the Sixth Circuit solidifies the principle that states cannot disregard federal court orders aimed at rectifying established constitutional rights, particularly those related to effective assistance of counsel in plea bargaining. It clarifies that the 'law and justice require' provision of the habeas statute grants broad remedial powers beyond mere physical custody, extending to the complete undoing of an unconstitutionally obtained conviction. Future cases involving state non-compliance with conditional habeas orders will find strong precedent for robust remedial action, although the specific issue of barring reprosecution remains context-dependent and requires explicit justification by the issuing court.
