Sanchez-Llamas v. Oregon
Encyclopedia
Sanchez-Llamas v. Oregon, 548 U.S. 331
(2006), was a case decided by the United States
Supreme Court
which held that a state court did not have to exclude evidence
admitted into court in violation of Article 36 of the Vienna Convention
.
, was convicted of attempted murder in Oregon
after engaging police in an armed confrontation. Mario Bustillo, a national of Honduras
, was convicted of murder in Virginia
for beating a man to death with a baseball bat. Neither man had his consulate informed of the charges against him, as is required by Article 36 of the Vienna Convention on Consular Relations.
John Roberts
, the Court held that states could admit evidence against defendants even if the evidence was obtained in violation of the Vienna Convention. The Court reasoned that the exclusionary rule is a rule idiosyncratic to American jurisprudence, and therefore, could not have been in contemplation by other nation-states when they ratified the Vienna Convention.
The Court also held that Article 36 claims which were not timely brought could be procedurally barred by state procedural default rules.
However, the Supreme Court was unwilling to rule as to whether or not Article 36 created individual rights that had to be honored in state criminal proceedings.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2006), was a case decided by the United States
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
which held that a state court did not have to exclude evidence
Exclusionary rule
The exclusionary rule is a legal principle in the United States, under constitutional law, which holds that evidence collected or analyzed in violation of the defendant's constitutional rights is sometimes inadmissible for a criminal prosecution in a court of law...
admitted into court in violation of Article 36 of the Vienna Convention
Vienna Convention on Consular Relations
The Vienna Convention on Consular Relations of 1963 is an international treaty that defines a framework for consular relations between independent countries...
.
Facts
Moises Sanchez-Llamas, a national of MexicoMexico
The United Mexican States , commonly known as Mexico , is a federal constitutional republic in North America. It is bordered on the north by the United States; on the south and west by the Pacific Ocean; on the southeast by Guatemala, Belize, and the Caribbean Sea; and on the east by the Gulf of...
, was convicted of attempted murder in Oregon
Oregon
Oregon is a state in the Pacific Northwest region of the United States. It is located on the Pacific coast, with Washington to the north, California to the south, Nevada on the southeast and Idaho to the east. The Columbia and Snake rivers delineate much of Oregon's northern and eastern...
after engaging police in an armed confrontation. Mario Bustillo, a national of Honduras
Honduras
Honduras is a republic in Central America. It was previously known as Spanish Honduras to differentiate it from British Honduras, which became the modern-day state of Belize...
, was convicted of murder in Virginia
Virginia
The Commonwealth of Virginia , is a U.S. state on the Atlantic Coast of the Southern United States. Virginia is nicknamed the "Old Dominion" and sometimes the "Mother of Presidents" after the eight U.S. presidents born there...
for beating a man to death with a baseball bat. Neither man had his consulate informed of the charges against him, as is required by Article 36 of the Vienna Convention on Consular Relations.
Procedure
Both Sanchez-Llamas and Bustillo filed state habeas petitions in their respective cases arguing that their right to consular notification had been violated. In both Oregon and Virginia the courts ruled that because these claims were not argued at the trial court level they were procedurally barred. The supreme courts of Oregon and Virginia both upheld the states' procedural bars. The two cases were then consolidated and argued before the United States Supreme Court.Holding
In an opinion by Chief JusticeChief Justice of the United States
The Chief Justice of the United States is the head of the United States federal court system and the chief judge of the Supreme Court of the United States. The Chief Justice is one of nine Supreme Court justices; the other eight are the Associate Justices of the Supreme Court of the United States...
John Roberts
John Roberts
John Glover Roberts, Jr. is the 17th and current Chief Justice of the United States. He has served since 2005, having been nominated by President George W. Bush after the death of Chief Justice William Rehnquist...
, the Court held that states could admit evidence against defendants even if the evidence was obtained in violation of the Vienna Convention. The Court reasoned that the exclusionary rule is a rule idiosyncratic to American jurisprudence, and therefore, could not have been in contemplation by other nation-states when they ratified the Vienna Convention.
The Court also held that Article 36 claims which were not timely brought could be procedurally barred by state procedural default rules.
However, the Supreme Court was unwilling to rule as to whether or not Article 36 created individual rights that had to be honored in state criminal proceedings.
See also
- List of United States Supreme Court cases, volume 548
- List of United States Supreme Court cases
- Breard v. GreeneBreard v. GreeneBreard v. Greene, , is a United States Supreme Court decision decided on April 14, 1998 which placed the United States directly in conflict with the International Court of Justice and has since been used as precedent.-Background:...
- Medellin v. TexasMedellín v. TexasMedellín v. Texas, 552 U.S. 491 is a United States Supreme Court decision which held that while an international treaty may constitute an international commitment, it is not binding domestic law unless Congress has enacted statutes implementing it or unless the treaty itself is "self-executing";...