Case Analysis Essay on Medellin v. Texas

Introduction

Medellin v. Texas involved Jose Medellin as the defendant and Texas as the plaintiff. According to the U.S Supreme Court ruling, the International Court of Justice (ICJ) decision in the Avena case (Mexico v. U.S) was not automatically irrevocable as domestic law in the United States. Also, the Supreme Court decided that the president was unable to discharge the decision against U.S states (McGuinness, 2008). The ICJ ruled that the U.S breached its obligations as stipulated by Article 36 of the Vienna Convention on Consular Relations (McGuinness, 2008). According to the Convention, the U.S was required to furnish consular notification to any foreigners who were arrested. Further, the U.S was supposed to evaluate and reconsider the convictions of the 51 individuals. This paper presents the facts in Medellin v. Texas.

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The defendant, Jose Medellin, was convicted of rape and murder and was sentenced to death. Medellin, in turn, petitioned a Texas court or habeas corpus citing that he was not informed about his prerogatives under the convention (Murphy, 2007). Since the U.S was involved in the Vienna Convention on Consular Relations, accused foreign nationals were free to contact their consulates. Medellin's right was violated. However, the Courts dismissed his appeal citing that the defendant had failed to raise his claims in earlier requests; hence the Convention violations could not affect the case's outcome. His application for certification to appeal to the circuit court was rejected because the Convention did not confer individual rights. The circuit court also upheld the decision that procedural-default rules applied to Convention claims. Medellin later petitioned for habeas corpus in state court based on President George Bush's memorandum that stated that the U.S would comply with its obligations under Avena through the state courts (McGuinness, 2008). However, Medellin's appeal was again rejected by the plaintiff with the conclusion that none of the memoranda (the President's and Avena's) was binding.

The issues before the court include whether state courts should, under the U.S Constitution, observe a treaty obligation of the U.S by discharging a settlement of the ICJ. Also in question is whether the state courts should, under the U.S Constitution, allow review and reconsideration of a sentence while disregarding state procedural default rules as stipulated by the President's memorandum. Chief Justice Robert decided against the first issue. According to the Vienna Convention, the authorities detaining a foreigner must acquaint the consular post of the detainee of the detention only if the detainee asks (McGuinness, 2008). The second issue was also decided against, and it was determined that the President's Memorandum was the Executive Branch's initiative to execute a non-self-executing pact and it lacked the required congressional action. C.J Robert's opinion was seconded by Justices Thomas, Kennedy, Alito, and Scalia.

Conclusion

Finally, dissenting opinions were voiced by Justice Breyer and seconded by Justices Souter and Ginsburg. These opined that according to the Supremacy law, the plaintiff should enforce the ICJ's judgment in Avena. The treaty obligation as represented by the Optional Protocol was self-executing. It means that legislative actions were unnecessary since the language underpins direct judicial enforcement. In keeping with the Presidential Memorandum, dissenting opinions pointed out that Congress neither authorized nor prohibited the activities that the Memorandum stipulated (McGuinness, 2008). Further, it was opined that the President, should, at some point, be allowed to assert foreign affairs powers within state proceedings.

References

McGuinness, M. E. (2008). Medellin v. Texas. American Journal of International Law, 102(3), 622-628.

McGuinness, M. E. (2008). Medellin v. Texas: Supreme Court Holds ICJ Decisions under the Consular Convention Not Binding Federal Law, Rejects Presidential Enforcement of ICJ Judgments over State Proceedings.

Murphy, J. F. (2007). Medellin v. Texas: implications of the Supreme Court's decision for the United States and the rule of law in international affairs. Suffolk Transnat'l L. Rev., 31, 247.