Robinson v. Thomas

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Petitioners, convicted of murder and sentenced to death, sought post-conviction relief in state court under North Carolina's Racial Justice Act (RJA), N.C. Gen. Stat. 15A-2010 to 2012. The state trial court awarded relief under the RJA and reduced petitioners' sentences to life imprisonment. The State appealed and the North Carolina Supreme Court vacated, remanding for additional RJA proceedings. Petitioners filed suit under 28 U.S.C. 2241 in federal court, arguing that a second RJA proceeding would violate their rights under the Double Jeopardy Clause of the Fifth Amendment. The district court abstained from exercising federal jurisdiction pursuant to Younger v. Harris, and alternatively held that petitioners failed to exhaust their state remedies. The court affirmed, concluding that the district court did not abuse its discretion by deciding to abstain because the basic requirements for Younger abstention were present in this case and petitioners failed to make a showing of extraordinary circumstances. The court rejected petitioners' claims to the contrary and affirmed the judgment. View "Robinson v. Thomas" on Justia Law