# Opposition — EDWARD H. SCHAD, JR. v. ARIZONA (No. 81-5919)

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Opposition
- **Published:** January 1, 1981

## Text

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JAN 1 8 1382

OFFICE OF THE CLERK
SUPREME COURT, U.S.

NO. 81-5919

IN THE SUPREME COURT OF THE UNITED STATES
October Term, 1980

EDWARD HAROLD SCHAD, JR.,
Petitioner,
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STATE OF ARIZONA,

Respondent,

ON WRIT OF CERTIORARI TO THE ARIZONA SUPREME COURT

RESPONSE TO PETITION FOR
WRIT OF CERTIORARI

ROBERT K. CORBIN
Attorney General of
the State of Arizona

WILLIAM J. SCHAFFER 111
Chief Counsel
Criminal Division

DAVID R. COLE

Assistant Attorney General
Department of Law

1275 W. Washington, 2nd Floor
Phoenix, Arizona 865007

Attorneys for RESPONDENT

1
1 TABLE OF CONTENTS
2 Page
3] TABLE OF CASES AND AUTHORITIES ii
4] QUESTIONS PRESENTED FOR REVIEW iv
5 [ STATEMENT OF THE CASE 1
6] JURISDICTION 1
7 ARGUMENTS
8 I
9 THE ARIZONA TRIAL COURT DID NOT VIOLATE
PETITIONER'S RIGHT TO CONFRONT WITNESSES
10 AGAINST HIM. 2
11 11
12 PETITIONER'S FOURTH AMENDMENT RIGHTS
WERE NOT VIOLATED WHEN LAW ENPORCEMENT
13 OFFICERS SEARCHED THE CAR THAT PETITIONER
TOOK FROM HIS VICTIM, AND SEIZED VARIOUS
14 ITEMS FROM THE CAR. 6
15 111
16 THE ARIZONA COURTS DID NOT PAIL TO
CONSIDER MITIGATING EVIDENCE OFFERED
17 BY PETITIONER. 0
18 Iv
19 THE ARIZONA COURTS DID NOT FAIL TO CONSIDER
EVIDENCE OFFERED BY PETITIONER, WHICH. “ME
20 ARGUED, SUGGESTED THAT CERTAIN AGGRAVATING
2 CIRCUMSTANCES SHOULD HAVE BEEN POUND. 9
v
22
THE ARIZONA COURTS DID NOT VIOLATE
23 THE RIGHTS CONFERRED UPON PETITIONER
BY THE EX POST FACTO CLAUSE OF THE
24 UNITED STATES CONSTITUTION. 10
25 | CONCLUSION 11
26
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28 1
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29
30 i
31
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TABLE OF CASES AND AUTHORITIES

Care ; Page
California v. Green

399 U.S. 149

90 S. ct. 1930

26 L. Kd. 2d 489 (1970) 4

Cotton v. United States
371 F.2d 385
(9th Cir. 1967) 7

Durham v. United States
401 U.S. 481
91 S. et. 858

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* 28 V. rd. 2d 200 (1971) 2
Gregg v. Georgia
11 428 u.. 153
96 S.Ct. 2909
12 49 V. FA. 2d 859 (1976) 11
13 Jones v. United States
362 U.S. 257
14 80 s. ct. 725
* 4 . rd. 2d 697 (1960) 7
Lockett v. Ohio
16 438 U.S. 586
98 S.Ct. 2954
17 57 . Kd. 2d 973 (1978) 8,9,10

18 Rakas v. Illinois
439 U.S. 128

19 99 S.Ct. 421
20 58 L.. E. 2d 387 (1978) 7
Robbirs v. California
21 6.8.
Ts. ct. 741
22 . . 24 (11981) 6,7
23] Simpson v. United States
346 . 2d 201
24 (10th Cir. 1965) 7
25 State v. Myers
117 Ariz. 79
26 570 p. 2d 252 (1977) 7,8
27 [state v. Watson
120 Ariz. 441
28 586 P. 2d 1253 (1978) 10,11
29} Taglianetti v. United States
4 394 U.S. 316
30 I 89 s. ct. 1099
31 22 L. Ed. 2d 303 (1969) 2
32

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Case

United States v. Atkins
618 F. 2d 366
(9th Cir. 1980)

United States v. Janerson
549 F.2d 1263
(9th Cir. 1977)

United States v. Wingate
520 F.2d 309
(24 Cir. 1975)

United States v. Zuroskyv
614 F.2d 779
(lst Cir. 1979)

AUTHORITIES

Arizona Rules of Evidence
Rule 804(B) (1)

Rules of the Supreme Court of the
United States
Rule 20
Rule 20.1
Rule 20.3
Rule 22

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QUESTIONS PRESENTED FOR REVIEW

1. Assuming, without conceding, that petitioner
presents a bona fide confrontation claim, did the Arizona
trial court violate petitioner's right to confrontation by
admitting certain testimony adduced at the voluntariness
hearing, where petitioner had sufficient opportunity and
motivation to develope the testimony he later wished to
adduce at trial?

2. Were petitioner's fourth amendment rights violated
when law enforcement officers searched the car that
petitioner had stolen from Leroy Grove?

J. Did the Arizona Supreme Court disallow
consideration of potentially mitigating evidence, or did
it merely agree with the trial court when it held that the
evidence presented, when duly considered, did not
constitute a mitigating circumstance?

4. Did the Arizona courts fail to consider evidence
and arguments relating to petitioner's prior conviction,
which conviction led to the finding of two aggravating
circumstances by the trial court?

5. Did the Arizona Supreme Court violate petitioner's
rights under the ex post facto clause of the United States
Constitution when it 1) declared that one portion of the
Arizona death penalty statute, which violated the mandates
of Lockett v. Ohio, was severable from the remainder of
the statute, and 2) held that petitioner was, in fact,
subject to a constitutionally valid death penalty statute?

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STATEMENT OF THE CASE

On August 9, 1978, the body of 74 year-old Lorimer
„Leroy“ Grove, a resident of Bisbee, Arizona, was found 9
miles south of Prescott, Arizona. From the the cord around
what was left of the victim's neck, the medical examiner
concluded that the killing was accomplished by means of
strsengulation.

Almost a month after this discovery, Petitioner Edward
Harold Schad was arrested in Salt Lake City, Utah. At that
time, petitioner was driving Mr. Grove's Cadillac. Between
the time when he took the car and the time of his arrest,
petitioner put several thousand miles on the car. He paid
for gasoline with the victim's credit cards. Between his

rrest and trial, petitioner told several highly
inconsistent stories regarding how he came into possession
of the victim's vehicle.

Petitioner was charged with first-degree murder in the
death of Leroy Grove. The jury, following a 2-week trial,
convicted petitioner of that crime. After considering the
aggravating evidence adduced by the state, and the
mitigating evidence offered by petitioner, the trial court
sentenced petitioner to death. Petitioner appealed his
conviction and sentence to the Arizona Supreme Court. That
court, after considering lengthy written briefs, and
hearing oral argument, affirmed petitioner's judgment and
sentence on July 13, 1981. Petitioner's motion for
rehearing was denied on September 10, 1981. Ninety-six
days later, he filed the instant petition for writ of
certiorari.

JURISDICTION

Petitioner cites Rule 20, Rules of the Supreme Court of

the United States, and several cases decided by this Court

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in support of his contention that, while his petition is
untimely, the defect is not jurisdictional end Gece not
prevent this Court from considering the petition. However,
it appears that the cases cited by petitioner, i.e. Durham
v. United States, 401 U.S. 481, 91 S.Ct. 858, 28 L.Ed.2d

200 (1971), and Taglianetti v. United States, 394 U.S. 316,

89 S.Ct. 1099, 22 C. Fd. 2d 302 (1969), were decided pursuant
to former Rule 22, not Rule 20. Rule 20, which is somewhat
different from former Rule 22, implies that untimely filing
may, in fact, constitute a jurisdictional defect. Rule
20.3 provides as follows:
The Clerk will refuse to receive any
petition for a writ of certiorari which
is jurisdictionally out of time.
Rule 20.1 provides that a 30-day extension may be obtained
when good cause is shown. It does not appear that
petitioner ever sought, much less secured, such an
extension.
Por these reasons, respondents respectfully request
this Court to dismiss the petition for writ of certiorari

for the reason that it was not filed in a timely fashion.

ARGUMENTS
I
THE ARIZONA TRIAL COURT DID NOT VIOLATE
PETITIONER'S RIGHT TO CONFRONT WITNESSES
AGAINST HIM.

Petitioner contends that the Arizona trial court
violated his .ight of confrontation when it admitted
testimony given at the suppression hearing by Kent Jones,
petitioner's former parole officer. Respondent disagrees
with petitioner's factual and legal analysis of this
issue. Respondent takes the position that petitioner

mischaracterizes this claim when he labels it a

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"confrontation" issue. ‘The simple fact is that appellant
failed to attempt to obtain Jones' presence at trial. In
order for this Court to understand respondent's approach to
this claim, certain background information is essential.

On September 21, 1979, the state made a motion to
continue petitioner's trial because Kent Jones had recently
been involved in a bad accident. Jones had already
testified at the hearing on petitioner's motion to
determine the voluntariness of certain statements that
petitioner had made. Petitioner's counsel, while
expressing sympathy for the state's position, objected to
the motion. The specific legal basis for nis objection was
petitioner's constitutional right to a speedy trial.
Petitioner's counsel was aware that the only alternative to
continuing the matter was to use the transcript from Jones“
suppression hearing testimony; nevertheless, he opposed
that alternative as well. On September 25, 1979, the state
reasserted its motion to continue. Petitioner withdrew his
objection to the motion. The state pointed out to
petitioner's counsel that, because of the trial court's
ruling regarding the inadmissibility of any evidence with
respect to petitioner's parole status, any testimony
related to that status would have to be introduced during
the defense case. Petitioner's counsel agreed with that
assertion. The trial court denied the motion to continue,
invoking petitioner's right to a speedy trial. The file
does not suggest that petitioner ever attempted to place
Jones under subpoena.

In admitting Jones prior testimony, the trial court

relied upon Rule 8048) (1), Arizona Rules of Evidence.

That rule provides as follows:

The following are not excluded by
the hearsay rule if the declarent is
unavailable as a witness:

1. Former testimony. Testimony
given as a witness at another hearing of
the same or a different proceeding, or
in a deposition taken in compliance with
law in the course of the same or another
proceeding, if the party againt whom the
testimony is now offered, or, in a civil
action or proceeding, a predecessor in
interest, had an opportunity and similar
motive to develope the testimony by
direct, cross, or redirect examination.

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It is undisputed that Jones vas not available for trial.
10} Even if this Court concludes that this is a legitimate
11} confrontation question, in spite of the fact that Jones
12] should have been subpoenaed by petitioner, the former

13 testimony was admissible under the above rule.

14] purthermore, its admission did not violate this Court's

15 pronouncemestts in California v. Green, 399 U.S. 149, 90

16] S.ct. 1930, 26 C. rd. 2d 489 (1970).

17 Respondent concedes that the “issue” in a voluntariness
18] hearing, as was held prior to trial in this case, is not

19 identical to the ultimate issue at trial, i.e. the guilt or
20 innocence of the defend it. However, the labels that are
21] attached to these issues should not be, and are not,

determinative of this question. More significant is the

question whether the party who opposes the introduction of
the former testimony at trial had sufficient opportunity

and motive to develop the testimony at the prior hearing.

)
United States v. Atkins, 618 F.2d 366 (9th Cir. 1980); |
United States v. Zurosky, 614 F.2d 779 (lst Cir. 1979)

cert. denied, 446 U.S. 967 (1980). Petitioner claims that

he wanted to cross-examine Jones at trial regarding the

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fact that petitioner was thought to be a “snitch” at the

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Utah State Penitentiary. This, according to petitioner,

would have bolstered the credibility of his trial testimony

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with respect to his explanation regarding why he made one
of several inconsistent statements about his possession of
Leroy Grove's car. As the Arizona Supreme Court pointed
out, this line of questioning was relevant to the issues
before the trial court at the voluntariness hearing.
Petitioner had opportunity and similar motive to develop
the testimony in question during the voluntariness hearing;
therefore, his right of confrontation was not violated.

The authorities cited by petitioner do not compel the
conclusion that petitioner's sixth amendment rights were

violated. United States v. Wingate, 520 Ff. 2d 309 (2d Cir.

1975), was decided strictly on the basis of the fact that
the issues at the pre-trial hearing and trial were not
identical. The court does not appear to have considered
the question whether the testimony at issue may have been
relevant both at the hearing and at trial. Here, as
respondent has urged, the testimony at issue was relevant
to the issues at the voluntariness hearing as well as to
issues raised at trial. Moreover, in Wingate, there was no
opportunity for the government to make the inquiries at the

pre-trial hearing. United States v. Atkins, supra,

supports respondent's position. There, the opposing party
had the opportunity, but not the motivation, to ask certain
questions of the witness who later became unavailable.
Here, petitioner had the opportunity and the motivation,
but did not avail himself of that opportunity. In United

States v. Zurosky, supra, as here, the inquiries were

relevant at the voluntariness hearing; for some reason,
defense counsel decided not to ask the questions.

Because of the rather peculiar things that happened
prior to petitioner's trial, respondent suggests that this

contention entitles petitioner to no relief because it does

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not even constitute a sixth amendment claim. In any event,
having had sufficient opportunity and motive to make the
inquiries at the pre-trial hearing, petitioner cannot now
Claim a violation of his right of confrontation.
11

PETITIONER'S FOURTH AMENDMENT RIGHTS

WERE NOT VIOLATED WHEN LAW ENFORCEMENT

OFFICERS SEARCHED THE CAR THAT

PETITIONER TOOK FROM HIS VICTIM, AND

SEIZED VARIOUS ITEMS FROM THE CAR.

Petitioner contends, largely on the basis of this

Court's holding in Robbins v. California, 9. 8s.

101 S.Ct. 28641. L. rad. 24 (1881), that he had
„Standing“ to contest the search of Leroy Grove's vehicle
and to object to the admission, at trial, of certain items
contained in that vehicle. For the first time, petitioner
has specified the objects which he felt were inadmise'ble
on the basis of a fourth amendment violation. (See
Petition for Writ of Certiorari, page 14.) Nonetheless,
given the facts of this case, respondent takes the position
that the Arizona Supreme Court properly ruled that
petitioner did not have a reasonable expectation of privacy
in Leroy Groves vehicle.

When Detective Johnson, Salt Lake City Police
Department, searched Grove's car on September 8, 1978, the
Gay petitioner was arrested, his purpose was to ascertain
ownership of the vehicle. This was Johnson's first contact
with the vehicle; several items were removed at that time
by Johnson and Detective Halterman. His only other contact
with the car was on October 18, 1978, at which time he did
not remove anything from the vehicle. He did not recall
any other officer removing anything from the vehicle at
that time. A search of a vehicle and its contents in order

to ascertain the identity or the whereabouts of the

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rightful owner is not improper. Haine v. State, 37 ud. App.
222, 377 A. 2d 509 (1978).

As he did in the Arizona Supreme Court, petitioner

places heavy reliance on Cotton v. United States, 371 F.2d

385 (9th Cir. 1967), and Simpson v. United States, 346 F.2d

291 (10th Cir. 1965). He now adds United States v.

Jamerson, 549 F.2d 1263 (9th Cir. 1977). As the Arizona
Supreme Court pointed out, this Court has characterized as
"inexplicable" the holdings in Cotton and Simpson, in that
they were apparently premised on a misinterpretation of

certain language employed by this Court in Jones v. United

States, 362 U.S. 257, 80 S.Ct. 725, 4 L. Fd. 2d 697 (1960).
Rakas v. Illinois, 439 U.S. 128, 142 n.9, 99 S.Ct. 421, 429

n.9, 58 L. Ed. 2d 387 (1978). Neither Cotton, Simpson, nor
Jamerson supports petitioner's argument. Petitioner's
statements that the search and seizure was “admittedly
unconstitutional,” and that he had “standing” to contest
the admissibility of the items seized, are inaccurate.
First, respondent has never conceded any impropriety in the
officers’ conduct. Second, in view of this Court's
language in Rakas and its stated intent to eliminate the
old “standing® concept in favor of substantive fourth
amendment analysis, petitioner's statements make no sense.
With respect to petitioner's reliance upon Robbins, it
is apparent that the officers in Robbins did not search the
automobile, or even any of its contents, for the purpose of
determining who owned the automobile. Indeed, ownership of
the vehicle involved in Robbins was never an issue.
Robbins does not appear to suggest that an individual can
wrongfully take a car from its owner, and gain a reasonable
expectation of privacy in the vehicle simply by driving it
around the country for 6 weeks. In State v. Myers, 117

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Ariz. 79, 570 P. 2d 252 (1977), cert. denied, 435 U.S. 928

(1978), the Arizona Supreme Court held that a car thief has
no reasonable expectation of privacy in a stolen vehicle.
The Myers holding is not at variance with any case relied
upon by petitioner. For these reasons, petitioner's fourth
amendment assertions do not warrant an order granting the
petition for writ of certiorari.
111

THE ARIZONA COURTS DID NOT FAIL TO

CONSIDER MITIGATING EVIDENCE OFFERED BY

PETITIONER.

Petitioner argues that the Arizona Supreme Court
"disallowed consideration” by the sentencing authority of
"doubt of guilt” as a mitigating circumstance.

Petitioner's argument is premised on a misreading of the
Arizona Supreme Court opinion, a misinterpretation of
decisions handed down by this Court, and an apparent
misapprehension of what happened in the trial court.

Respondent's reading of the Arizona Supreme Court's
opinion discloses no suggestion that the court disallowed
anything as a consideration in cases where the death

penalty is available. In Lockett v. Ohio, 438 U.S. 586, 98

J. ct. 2954, 57 L. FA. 2d 973 (1978), this Court held that the
sentencing authority could “not be precluded from

considering as a mitigating factor any aspect of a

G@efendant's character or record and any of the
circumstances of the offenses that the defendant profers as
a basis for a sentence less than death." 438 U.S. at 610,
96 S.Ct. at 2967 (emphasis original). Petitioner equates
this language with a pronouncement that the sentencing
authority must find mitigating circumstances from the
evidence presented. That is clearly not what this Court

said; indeed, common sense dictates that these two

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concepts - consider at ion“ of possible mitigating evidence
and acceptance“ of the evidence as valid mitigation--are
two different things. The record is clear that petitioner
presented evidence and argument relating to the “doubt of
guilt” theory, including the testimony of the alternate
juror. Pursuant to Lockett, it was a legitimate area of
inquiry. However, the trial court was not constitutionally
mandated to find, nor did it find, that this theory of
mitigation rose to the level of a mitigating circumstance.
Twelve jurors found, beyond a reasonable doubt, that
petitioner committed the crime of murder in the first
degree. The alternate juror, who never examined many of
the exhibits introduced at trial, and who never had the
opportunity to deliberate the matter with 11 other
individuals, believed that the evidence was insufficient to
warrant conviction. The trial judge disagreed. The
Arizona Supreme Court, in its independent examination of
the record, agreed with the trial court. Petitioner's
exhortations to the contrary, both Arizona courts

considered the proffered evidence. The fact that neither

court found that the evidence constituted a mitigating
circumstance does not violate the mandate of Lockett or any
known constitutional precept.
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THE ARIZONA COURTS DID NOT FAIL TO

CONSIDER EVIDENCE OFFERED BY PETITIONER,

WHICH, HE ARGUED, SUGGESTED THAT CERTAIN

AGGRAVATING CIRCUMSTANCES SHOULD NOT

HAVE BEEN FOUND.

Petitioner's murder of Leroy Grove was not his first
violent act. In 1968, he was convicted of second-degree
murder. Both of petitioner's victims were strangled. He
now claims that the Arizona courts failed to consider the

extent ot degree of proof upon which his prior conviction

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was premised. This contention is separate from the one
advanced in Argument III. Argument III deals with the
alleged failure of the Arizona courts to consider evidence
offered in mitigation of the offense; this argument
involves the alleged failure of the state courts to
consider evidence that might eliminate, or at least dilute,
aggravating evidence proffered by the state. Even if
Lockett applies to this situation, as opposed to a
situation where the defendant is precluded from offering
evidence in mitigation of the offense, petitioner again
equates two distinct and unequal concepts. Petitioner was
not foreclosed, by the trial court or the Arizona Supreme
Court, from either presenting evidence with respect to his
prior conviction or arguing that the prior conviction
should not be found to constitute an aggravating
circumstance. The fact that neither court agreed with
petitioner's argument does not mean that he was foreclosed
from making this argument.
*

THE ARIZONA COURTS DID NOT VIOLATE THE

RIGHTS CONFERRED UPON PETITIONER BY THE

EX POST FACTO CLAUSE OF THE UNITED

STATES CONSTITUTION.

The short answer to petitioner's argument is that the
Arizona death penalty statute was never held to be
unconstitutional. Part of the statute was found to violate
this Court's mandate in Lockett, but the Arizona Supreme

Court held that that portion of the statute was severable

from the rest. State v. Watson, 120 Ariz. 441, 445, 586

p. 2d 1253, 1257 (1978). Thus, there was a valid death

penalty statute in effect on August 1, 1978, when
petitioner killed Leroy Grove. The argument that the

Watson Court improperly "rewrote" the death penalty statute

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totally disregards the severability concept as set forth in
Watson and other decisions. Petitioner has not explained,
nor does respondent understand, how the Arizona Supreme
Court's holding in Watson violates anything this Court said

in Gregg v. Georgia, 428 U.S. 153, 96 S.Ct. 2909, 49

L. Ed. 2d 859 (1976).
Lastly, the imposition of the death penalty does not

violate petitioner's rights under the ex post facto clause

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of the United States Constitution. The Watson opinion was
10} filed 12 days before petitioner committed his crime. Thus,
il} in legal contemplation, he was on notice that the State of
12] Arizona had the authority to seek the death penalty for
13} persons convicted of first-degree murder. For this reason
14] and those given above, neither the ex post facto clause,

15} nor any of the decisions interpreting it, were violate4

16 here.
17 CONCLUSION
18 For the reasons stated, respondent respectfully

19] requests this court to deny the petition for writ of

certiorari.
Respectfully submitted,

ROBERT K. CORBIN
22 Genera

WILLIAM J. SCHAFER 111
Chief Counsel
Criminal Division

Frat e.

DAVID R. COLE
Assistant Attorney General

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Attorneys for RESPONDENTS

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AFFIDAVIT

STATE OF ARIZONA )
COUNTY OF MARICOPA =

DAVID R. COLE, being first duly sworn upon oath,
deposes and says:

That he served petitioner in the foregoing case by
forwarding one (1) copy of RESPONDENT'S RESPONSE TO WRIT
OF CERTIORARI; and also served the attorney for the
petitioner in the foregoing case by forwarding two (2)
co, ies of RESPONDENT'S RESPONSE TO WRIT OF CERTIORARI, in
a sealed enve lobe, first class postage prepaid, and

deposited same in the United States mail, addressed to:

CHARLES A. SHAW EDWARD HAROLD SCHAD, JR.
122 N. Cortez, Suite 300 Box B-40496
Prescott, Arizona 86301 Arizona State Prison

Florence, Arizona 85232
Attorney for PETITIONER

this 13th day of January, 1982.

SUBSCRIBED AND SWORN to before me this 13th day of

January, 1982.

. : /
, sil / :
Zu Ce
NOTARY PUBLIC Cs
My Commission Expires: f

May 17, 1983 N
PH-1709G N

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385008_1807%3A3. Public record. Not legal advice.