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When a Judge uses Marijuana?is the Trial Unfair?

What do you get when you combine a dope-smoking judge, a romantic interlude between a prosecutor and defence counsel, a ?psychic tip? which leads police to the murderer and a ?functionally retarded? defendant with an explosive personality disorder?

The case that led a federal appeals court to overturn death sentences in Arizona was described in the ruling by the 9th U.S. Circuit Court of Appeals as “the raw material from which legal fiction is forged:

“A vicious murder, an anonymous psychic tip, a romantic encounter that jeopardised a plea agreement, an allegedly incompetent defence and a death sentence imposed by a purportedly drug-addled judge.”

The facts of the crime are brutal. But the legal proceedings that followed caused the court to quote Mark Twain, who observed that “truth is often stranger than fiction because fiction has to make sense.”

Warren Summerlin was convicted of the 1981 killing of Brenna Bailey, a 36-year-old finance company administrator who had come to his house to discuss money owed on a loan. Her partially nude body was found about a mile away from the Summerlin home in Tempe, Arizona, a day after she disappeared.

Before the body was discovered, a police tip line received a call from Summerlin’s mother-in-law accusing him of murder based on her daughter’s psychic abilities.

If you guessed a story so strange that not even a crack team of soap opera writers could dream up, you win the prize.?The best place to start with this Odyssey (that?we will not?call a long, strange trip) is at the beginning.
Brenna Bailey worked?for Finance America in Phoenix, Arizona. On a fine spring morning in 1981, Brenna decided to do some face-to-face collecting of some delinquent accounts, including one belonging to Warren Summerlin?s wife. She set out on April 29 to visit her clients and after making a couple of stops, she disappeared.

Her boyfriend at the time, Marvin Rigsby, started doing some skip-tracing of his own after he was unable to get in touch with her and he learned that she had not returned to work as she had planned. He got the list of places Brenna planned to visit and started to investigate. Retracing her route, he spoke with Summerlin on the evening of the 29th and was told that Brenna had been there, but left about 10:30 a.m. The woman who was next on the list of persons to be visited claimed Brenna never showed up. She had been home all day and had received no visitors.

Rigsby went to the police, who had also received a tip on their anonymous tip-line from someone who claimed that ?the missing woman from Pacific Finance Company? had been murdered by Summerlin and her body rolled up in a carpet. The caller turned out to be Summerlin?s mother-in-law, who told authorities that her daughter ?had ESP? and had sensed the crime.
The day after police received the anonymous psychic tip, a paving crew working outside a store near the Summerlin residence pointed out a brown Mustang in the store parking lot to the store’s manager. Id. The store manager had served in Vietnam and recognised the smell of a decaying body emanating from the car. The store manager also saw a pair of women’s underwear and shoes in the back seat of the car and called the police.

In the back of the car, police found women?s underwear, nylons, and shoes. Forcing open the trunk, the investigators found Brenna Bailey?s partially nude, bloody body, wrapped in a bed sheet. Her skull was crushed.

When the police showed up at Summerlin?s home with a search warrant, his first response to them was ?I didn?t kill nobody.? He then asked, ?Is this in reference to the girl that was at my house??

?What girl?? the officer asked.

Summerlin described Brenna Bailey.

A search of the residence found numerous pieces of incriminating evidence and Summerlin?s wife identified the bed sheet found with the victim as one coming from the home. What role her real or imagined ESP had played in the tip was never explored and Mrs Summerlin was not charged with any wrongdoing. When Summerlin was arrested, he asked to speak to his wife. In the presence of police, he made several incriminating statements.

During the trial, Detective Fuqua of the Phoenix Police Department testified that when Summerlin and his wife were together, clearly in the presence of police officers, Summerlin said, “I knew this had to happen.”
Summerlin’s wife then responded, “What do you mean?” and Summerlin replied, “This was a big crime.”

Summerlin’s last statement was, “I don’t like to pay bills and all the other bullshit.” Just before the interview ended, Summerlin told his wife not to worry because the police would not find anything in the house.

So far, the case of Warren Summerlin was shaping up to be a simple, tragic and regrettable run-of-the-mill murder case. The evidence was all good and conclusive, the searches were legal, he had been Mirandized appropriately and treated well in custody. Law enforcement had done its job well, but the criminal justice system was about to have its way with Warren Summerlin.
Indicted on capital?murder?charges, Summerlin was assigned a lawyer from the capital crimes section of the state public defender?s office. After a couple of meetings with his client, the attorney requested a mental competency evaluation, which was scheduled. Summerlin?s first attorney subsequently left the public defender?s office, and another public defender was assigned.

In the summer of 1981, two psychiatrists examined Summerlin and found that he had suffered a brutal and cruel childhood, suffered from dyslexia and had dropped out of school in the 7th grade, but under the McNaughton standard which determined a defendant?s legal?sanity, Summerlin was sane when he allegedly committed the offense and reported that he was competent to stand trial.

Warren Wesley Summerlin.

There is no doubt that Warren Summerlin is an extremely troubled man. He has organic brain dysfunction, was described by a psychiatrist as “functionally retarded,” and has an explosive personality disorder with impaired impulse control. His father was a convicted armed robber who was killed in a shootout. As a youth, his alcoholic mother beat him frequently and punished him by locking him in a room with ammonia fumes. At his mother’s behest, he received electroshock treatments to control his explosive temper. He dropped out of school in the seventh grade due to dyslexia and committed numerous petty juvenile offences. In 1975, he was diagnosed as a paranoid schizophrenic and treated with the antipsychotic medication Thorazine.

An electroencephalogram showed some dysfunctional processing in Summerlin?s posterior?temporal area but was not found to be sufficient to cause either epilepsy or temporal lobe seizure.
Psychological testing found that Summerlin was ?deeply emotionally and mentally disturbed, unaware of the motives underlying much of his behaviour, and unable, because of his problems, to exercise normal restraint and control once his highly unstable and volatile emotions are aroused.?

His formal diagnosis was organic brain impairment with borderline personality disorder and paranoid personality disorder. Again, that?s not enough to support an insanity defence. A Maricopa County Superior Court Judge formally found Summerlin competent to stand trial in November 1981.

The open-and-shut case with a defendant who had a boat-load of mitigating factors was a lose-lose proposition for both the State of Arizona and the public defender. There was almost no chance Summerlin was going to beat the rap, but there was a good chance that under the sentencing scheme then in place in Arizona, a judge would find the mitigating factors outweighed the aggravating ones and Summerlin would not be sentenced to death.

Starting from the solid premise that the case did not warrant the extra time and expense connected to a capital case, the two sides started negotiating a plea.

On November 17, 1981, the prosecutor, whom appellate court records name only as ?John Doe? and the defense attorney, known as ?Jane Roe? reached a deal that would have Summerlin plead no contest to second-degree murder and aggravated assault, with 21-year term for Brenna Bailey?s murder, and a maximum 15-year term for an unrelated road rage incident which led to the aggravated assault charge. The sentences would be served concurrently and Summerlin would be required to serve at least 14 years.

The final approval, of course, was not Summerlin?s but the judge?s, and the deal allowed him to reject the stipulated sentence. Prosecutor Doe did not believe that Summerlin?s case was a capital offence, so even if the judge rejected the sentencing stipulation, the most Summerlin could have gotten was 38-and-a-half years.
Compared to a trip to the electric chair, Summerlin, functionally retarded or not, should have taken the deal and run. At first, he did so. He took the?Alford (no contest) plea, (Also known as a ?best-interests plea,? an Alford plea registers a formal claim neither of guilt nor innocence toward charges brought against a defendant in criminal court) but a few days later ? he had not yet been sentenced ? he filed a?pro se?motion to withdraw the plea and asked to fire his public defender.

On December 15, 1981, the judge in the case denied Summerlin?s motion but advised him at that time that he was seriously looking at not accepting the stipulated sentence as recommended by the State. If the judge did deviate from the plea agreement, Summerlin could at that point withdraw the guilty plea and go to trial.
Defence attorney Roe, fearing that the judge was going to reject the sweetheart deal, and would push Summerlin into going to trial where they would recommend a death sentence, quickly moved to have the case transferred from that judge because of prejudice against her client. The senior judge in the Maricopa County Superior Court declined to do at a hearing on December 18.?All of this intense work together to wrap up Summerlin?s case overflowed into a boozy Christmas party romantic pas de deux between Doe and Roe the night the presiding judge declined to remove Summerlin?s judge.

The next morning, Roe went to her boss, and confessed, and said she could no longer ethically represent Mr Summerlin. For reasons that will be made plain, Mr Doe did not go to his boss. Ms Roe would later testify that because of the circumstances, ?it would be appropriate for another public defender to handle the case and take it to trial since it looked like it might be a trial at that point.?

The public defender supervisor decided that the entire office might have been compromised and thus Summerlin would have to have special counsel appointed.
However, neither Roe nor Doe took any steps to remove themselves from the case, and it must have been a pretty awkward hearing before Judge Derickson on December 22, 1981. After a lengthy hearing, the judge accepted Summerlin?s request to withdraw the guilty plea.

On December 28, 1981, Roe and Doe met to discuss the situation. Roe was planning to withdraw, but she wanted Doe to remain on the case because he didn?t feel the case was a capital crime and was in favour of a lesser plea. They arranged for a hearing before the trial judge who held a private meeting with counsel and then in public appointed private attorney George Klink to represent Summerlin at his trial.

The dalliance between attorneys probably merited them a penalty from the Bar Association, but it had little impact on his case once the judge rejected the plea deal and new lawyers were brought in. The fate of their relationship remains one of the unexplored mysteries of their case. The hook-up would feature prominently in appeals, however.
The case was set for trial before Judge Philip Marquardt. A little more than a month later, the Arizona Attorney General?s Office assumed responsibility for prosecuting the case, and indicated that it was not going to accept any plea offers.

Klink met with Summerlin?s former counsel regarding his client?s psychiatric profile, but when it was clear that an insanity defence would not apply, he did not pursue this avenue further. The case went to trial, with Klink offering the theory that there was no premeditation involved. When the prosecution presented witnesses who provided evidence that Bailey had been raped by his client, Klink, on cross-examination, tried to refute the lack of rape evidence to bolster his position of no premeditation.
Without premeditation, there was no capital crime and Summerlin would not be executed. The case against the man was strong enough to leave just that single option.
The state did not present any psychological or psychiatric evidence, which limited Klink?s ability to bring up Summerlin?s background and emotional disability. In the end, the evidence was simply overwhelming and the jury came back with a guilty verdict on capital murder. Judge Marquardt set the matter for a sentencing hearing the following month.

At that time, in Arizona, the judge, not a jury, determined whether there were enough aggravating factors to merit the death penalty.
In the month between the verdict and the hearing, Klink?s representation bordered on ineffective. He did not meet with his client, nor did he meet with any of the psych experts that the Attorney General was planning to call.

During the sentencing hearing Klink did not introduce Summerlin?s side of the aggravated assault conviction. In that case, Summerlin?s wife had been struck by a car that left the road and he reacted by pulling a knife on the driver. The driver was not hurt, but simply pulling a weapon constituted aggravated assault. The conviction was used as an aggravating factor.

Aggravating circumstances are not separate penalties or offences but are standards to guide the making of (the] choice between the alternative verdicts of death and life imprisonment. Thus, under Arizona’s capital sentencing scheme, the judge’s finding of any particular aggravating circumstance does not of itself ‘convict’ a defendant (i.e., require the death penalty), and the failure to find any particular aggravating circumstance does not ‘acquit’ a defendant (i.e., preclude the death penalty).

In addition, Klink provided no evidence of Summerlin?s horrendous childhood.
Judge Marquardt heard the state?s case on July 8, 1982. It was an extremely short hearing, after which Klink called a psychologist to the stand and prepared to question him. Summerlin objected to this, and Judge Marquardt called a recess. When court resumed, Klink rested without asking any questions. The judge then advised the parties that he would rule on the standard motion for a new trial and hand down his sentence on Monday.

However, Judge Marquardt was a heavy marijuana user at the time, and would later admit that he was addicted to pot. His addiction had had an effect on the trial proceedings, a federal court later found.

There are instances during pre-trial hearings and at trial when Judge Marquardt exhibited confusion over facts that had just been presented to him. He also made some quite perplexing, if not unintelligible, statements at various times during the trial. Obviously, because there was no discovery or evidentiary hearing permitted, the question of whether these episodes were related to impairment was, and is, unresolved

(In his disbarment proceedings, Judge Marquardt admitted he was addicted to marijuana but did not indicate how long he had been addicted.)

A report from the Phoenix Police Department dated June 3, 1991, showed Judge Marquardt had purchased marijuana through the United States mail in May 1991, which was intercepted by police. When the delivery did not arrive, Judge Marquardt called his supplier to see if she had informed the authorities. She said she had not and Judge Marquardt told her that everything would be alright because his daughter’s boyfriend Butch “was going to take the wrap for the marijuana.”In the police report, Judge Marquardt’s marijuana supplier said Judge Marquardt “was a frequent user of marijuana, had been when she met him [sixteen years earlier], and has continued to be so since.” Judge Marquardt had also sent a cashier’s check to his supplier for the marijuana in an official envelope with the heading “Phillip Marquardt, Superior Court Judge, Phoenix, Arizona.” In a previous incident, Judge Marquardt was convicted in Texas in 1988 of possession of marijuana when it was found on his person at a port of entry in Houston, but he claimed that a stranger had approached him and stuck a small plastic bag in his pocket. For this incident, he was suspended without pay for one year but continued to use marijuana.

?There are instances during pre-trial and at trial when Judge Marquardt exhibited confusion over facts that had just been presented to him,? the Ninth Circuit Court of Appeals wrote in one of Summerlin?s subsequent appeals. ?He also made some quite perplexing, if not unintelligible, statements at various times during the trial.?

On the following Monday, Judge Marquardt forgot about the new trial motion and went right to sentencing. At that hearing, Summerlin, the ?functionally retarded? and emotionally disturbed murderer, appeared to be the only person in the courtroom who had a clue about procedure, or who at least was not high or daydreaming about last weekend.
Judge Marquardt asked Summerlin if there was any reason why sentence should not be handed down. Klink responded that he knew of no legal cause. Summerlin said that there was a pending motion to vacate the verdict still unresolved. Judge Marquardt took a 5-minute recess and came back to the bench, denied the motion to vacate and sentenced Summerlin to death.

The amount of marijuana that Judge Marquardt may have used during the trial or deliberations is unknown because the district court did not allow discovery on this issue, although there is record support for Summerlin’s claim that Judge Marquardt was either having difficulty concentrating or experiencing short-term memory loss.

It was Judge Marquardt?s second death sentence of the day (curiously, both victims were named Bailey), and there is some indication that the judge confused the facts of the two cases. The other death sentence handed down that day was overturned on appeal because Judge Marquardt had allowed an unethical plea deal.

On the same day of Summerlin’s sentencing, Judge Marquardt also sentenced James Clifford Fisher to death. Fisher also murdered a woman whose last name was Bailey (no relation to Brenna Bailey) with a blunt instrument. ?Judge Marquardt also found two aggravating factors in Fisher’s case just as he did in Summerlin’s-including that the crime was committed in an especially heinous and depraved manner-and found no mitigating circumstances sufficient to call for leniency.

Due to such unusual events, Judge Thomas of the United States Court of Appeals for the Ninth Circuit described Summerlin’s case as follows: It is the raw material from which legal fiction is forged: A vicious murder, an anonymous psychic tip, a romantic encounter that jeopardized a plea agreement, an allegedly incompetent defense, and a death sentence imposed by a purportedly drug-addled judge. But as Mark Twain observed, “truth is often stranger than fiction because fiction has to make sense.”
Summerlin appealed his sentence, and the Arizona courts upheld the conviction and sentence on appeal. He filed for?habeas corpus?relief (A civil lawsuit specifically permitted by federal law in which a defendant can challenge in federal court his or her state conviction or sentence based on alleged violations of the defendant?s constitutional rights) in the federal courts and an entire course on appellate law could be taught based on Summerlin?s trips up and down the federal courthouse steps.

Suffice to say that on October 17, 2005, twenty-four years after Brenna Bailey was murdered, ten years after Summerlin might have been released had he accepted the plea deal (and two-thirds of the way through the maximum sentence that deal could have brought), the Ninth Circuit Court of Appeals granted Summerlin?s petition for a writ of habeas corpus and ordered a new sentencing hearing.

Judge Sidney R. Thomas summed up the court?s feelings about the case: ?Extraordinary plotlines rarely end; they frequently reappear in sequels; thus this case returns to us from the Supreme Court to write the next chapter in this unusual saga.?

“I thought legal highs were banned now, Sarge?”

Twenty-nine years ago, Superior Court Judge Philip Marquardt got busted while attempting to sneak some dope past customs officials after a Mexican vacation. That netted him a misdemeanour conviction, a $500 fine, a year’s suspension from his job ? and quite the scandal. It’s a bizarre story. (Who tries to buy pot by mail and seriously thinks he’ll get away with it?)

Judge Marquardt bought marijuana by mail. He paid with a cashier’s check, and he used the office stationery. The envelope bore a handsome imprint: ”Philip Marquardt, Superior Court Judge, Phoenix, Arizona.”

Mr Marquardt lost that job and his license to practice law after his second marijuana conviction, in 1991, and by 2002 was a retired ski instructor. In 2002, the two men he sentenced to death in the 1980’s asked the courts to look into whether his use of marijuana deprived them of a fair trial.

Their assertions test attitudes about whether using drugs while not working should be of concern in the workplace, about how much extra scrutiny is warranted in death penalty cases and about the limits of judicial privacy. Judges and prosecutors worry that allowing criminal defendants to examine the human element in the judicial process will have enormous consequences.

”There is a floodgate that can be opened here,” said Robert L. Ellman, an Arizona assistant attorney general.

When a federal appeals court ordered a hearing to consider evidence about the assertions of one of the prisoners, Warren Summerlin, the majority quoted Shakespeare:

He who the sword of heaven will bear

Should be as holy as severe

When ?Superior Court Judge Philip Marquardt resigned he said:

“I have a serious problem, an addiction to marijuana,” A recovering alcoholic, the judge said he remained sober for many years before he began using marijuana as a substitute for alcohol. He apologised to his fellow judges and to the voters and asked for their understanding. “I did not fail them as a judge, I failed them as a human being,” he said.

The dissenting judge on the three-judge panel, Alex Kozinski, noted that there was no proof that Judge Marquardt’s drug use had affected his performance on the bench, and he said the decision invited intrusion into judges’ personal lives.

”Judges rightly expect to have medical histories, family tragedies, even occasional overindulgences in intoxicating substances, remain private,” Judge Kozinksi wrote. John Pressley Todd, another assistant attorney general, said there was no principle to distinguish questions about Judge Marquardt’s marijuana use from inquiries into all sorts of matters that might influence judicial decision making.

Steven Lubet, a professor at Northwestern University Law School, said unwarranted intrusions were a real danger.

”Desperate defendants should not be allowed to rummage through judges’ personal lives,” Professor Lubet said. But he disagreed with the assertions involving Judge Marquardt, saying, ”Wherever the line is, it is somewhere well short of a double conviction for illegal drugs.”

Mr Marquardt conceded in an interview that he used marijuana regularly in the years in which he sentenced the two men to death. Sipping a soft drink by the pool at a golf resort outside town, Marquardt talked about his past and its significance for the men he sentenced to death. He acknowledged once having had a taste for the fast life, ”but it never carried onto the bench,” he said.

Marquardt, spent 20 years on the bench, is fit and vigorous, and he was in a reflective mood. ”By the very nature of marijuana you don’t wake up drugged up or glazed over,” he said. ”I walked into the courtroom clear-headed, clear-eyed and absolutely in control of my intellectual abilities.”

Richard Michael Rossi, whom Mr. Marquardt sentenced to death in 1988, spoke by phone from death row in Arizona State Prison, said of the judge: ”There is a lot of ironies here. We both had addiction problems. I acknowledged mine. He didn’t acknowledge his.”

At his sentencing hearing for killing a man in a dispute over the sale of a typewriter in 1983, Rossi submitted a doctor’s report seeking leniency based on his cocaine addiction. But Judge Marquardt took the opposite view at the court hearing, saying, ”I want it to be clear that this court finds that the cocaine addiction does not negate the factors of the cruel, heinous or depraved factors.”

Three years later, Judge Marquardt hired Rossi’s doctor to prepare a report in connection with his own sentencing on drug charges, seeking leniency on the basis of marijuana addiction. He now regretted that Marquardt said; ‘marijuana is just not that addictive.”

In addition to agreeing to resign his judgeship, Mr Marquardt was sentenced to probation, fined $20,000 and forced to give up some of his retirement benefits. For his first offence, which was in 1988, a month after Rossi’s hearing, Marquardt was given a suspended sentence. He was later suspended from the bench without pay for a year by the Arizona Supreme Court.

Judge Marquardt also decided the fate of Mr Summerlin, who was convicted of sexually assaulting and then killing a debt collector in 1981. On a scorching Friday in the summer of 1982, Judge Marquardt heard final arguments on whether Mr Summerlin should be put to death, and, he said, ”over the weekend.”

Two decades later, the appeals court focused on that comment. The majority was troubled, it wrote, ”by the fact that Judge Marquardt deliberated and made the key life or death decisions in this case ‘over the weekend,’ while not on the bench or on public view.”

Mr Marquardt said he did not recall that particular weekend, but added, ”I certainly haven’t admitted using marijuana on the bench or during my deliberations.”

Judge Kozinski wrote that ”no doubt hundreds” of convicted criminals might challenge the fairness of their trials before the former judge. While Mr Marquardt defended his conduct on the bench, he said he believed an inquiry into it was appropriate: ”When you have initial proof, as Summerlin does, that the judge who sentenced him used drugs, I think that triggers an entitlement to ask questions.”

”If it is against the law to drive a vehicle under the influence of marijuana,” the majority said, ”surely it must be at least equally offensive to allow a judge in a similar condition to preside over a capital trial.”

Judge Kozinski wrote that Summerlin should have offered specific evidence of on-the-job intoxication before the court ordered a hearing. He gave several examples of possible proof. One was a statement by a courtroom observer that the judge fell asleep in court.

Rossi, whose appeal is pending before the same court, said he had offered such proof. Judge Marquardt had not presided over Mr Rossi’s trial, but it fell to the judge to resentence him in 1988 after the Arizona Supreme Court reversed a previous death sentence. The hearing started at 11:30 a.m., paused at noon for a two-hour break and ended at 4:40.

Mary Durand, an investigator who was a member of Mr Rossi’s defence team and was at the hearing, said Judge Marquardt slept through much of it. ”This was not a two-minute nod-off after lunch,” Ms Durand said. ”This was slumber.” She estimated that the judge slept for 30 minutes at one point, woke up and fell asleep again. She took notes at the hearing. They concluded, ”Pity Marquardt slept thru most of this!”

Mr Ellman, who represents the state in Mr Rossi’s appeal, has reviewed the transcript of the hearing. He said there was no support in it for Ms Durand’s assertion. ”The judge appears to be very coherent and tracking the evidence accurately,” Mr Ellman said.

Mr Rossi recalled his frustration. He said he and Ms Durand cleared their throats loudly, banged pens on the table and tried to get the court clerk’s attention, all to no avail.

Mr Rossi said he deserved a hearing to examine whether marijuana played any role in his death sentence.

In his dissent in the Summerlin case, Judge Kozinski questioned just what such a hearing might show.

”Even if Judge Marquardt did think about Summerlin while under the influence of marijuana, it’s not clear why this would taint his decision,” he wrote. ”Does having a fleeting thought on a subject while intoxicated then vitiate all of a judge’s sober deliberations? Or is the test whether the judge actually made up his mind under the influence? How would one know?”

A 2002 U.S. Supreme Court decision was cited in the appeal’s court overturning Summerlin’s death sentence. The court ruled that the Sixth Amendment right to a trial by jury also required a jury to decide capital sentences, saying “a judge sitting without a jury cannot constitutionally enter a judgment of conviction for capital murder.”Although Summerlin was convicted before the ruling, the appellate court applied it retroactively.

The appellate ruling also said that if the allegations of the trial court judge’s drug use were true, it would mean that Summerlin’s fate was determined by a drug-addled judge who treated death penalty phase cases the same as non-capital sentencing trials and who relied on inadmissible evidence.

The ruling noted that while no system was perfect, allowing a panel of 12 jurors to impose capital punishment reduced the risk of error, because the panel must agree on aggravating factors beyond a reasonable doubt, because their job security is not threatened by the trial’s outcome, and because they may only consider evidence subject to the rigors of cross-examination.

Marquardt conceded in an interview that he used marijuana regularly in the years in which he sentenced the two men to death. While he defended his conduct on the bench ? saying he has never admitted using marijuana on the bench or during deliberations.

Judge’s Drug Use at Issue in 2 Death Sentences – The New York Times

Pot clouds judge’s death row verdicts –

The Supreme Court finds its happy ending.

Killer on death row to be resentenced to life term – Tucson Citizen … – A case stranger than fiction – Sep. 3, 2003

Warren Summerlin | Murderpedia, the encyclopedia of murderers

The Supreme Court finds its happy ending.

Stranger than Fiction | – The Malefactor’s Register

Encyclopedia of Capital Punishment in the United States, 2d ed.

Judge’s Drug Use at Issue in 2 Death Sentences – The New York Times

Schriro v. Summerlin – Via Sapientiae – DePaul University

LEGAL UPDATES: Mental Retardation, Representation, Lethal Injections

Criminal Law – The Final Battle in a Two-Front War over Judicial Death …

JURIST – Bickers: Maybe Death Isn t So Different After All

Schriro v. Summerlin – Case Brief –

Stranger than Fiction | – The Malefactor’s Register