Citation. Medellin v. Texas, 128 S. Ct. 1346, 552 U.S. 491, 170 L. Ed. 2d 190, 2008 U.S. LEXIS 2912, 76 U.S.L.W. 4143, 2008-1 U.S. Tax Cas. (CCH) P50,242, 21 Fla. L. Weekly Fed. S 126 (U.S. Mar. 25, 2008)
Brief Fact Summary. Jose Medellin (D) appealed after Texas (P) convicted him of rape and murder on the ground that the plaintiff failed to inform him of his right to have consular personnel notified of his detention by the state as it was required under the Vienna Convention. During his appeal at the Supreme Court, Medellin (D) argued that a case decided by the international Court of Justice suggested that his conviction must be reconsidered to comply with the Vienna Convention.
Synopsis of Rule of Law. (1). States courts are not required under the U.S. Constitution to honor a treaty obligation of the United States by enforcing a decision of the International Court of Justice.
(2) State courts are not required by the U.S. Constitution to provide review and reconsideration of a conviction without regard to state procedural default rules as required by a Memorandum by the President.
Facts. Jose Medellin (D), a Mexican national was found guilty for being part of the gang rape and murder of two teenage girls in Houston. He argued that the state had violated his rights under the Vienna Convention in which the United States is a party. Under the Vienna Convention, any foreign national detained for any crime has a right to contact his consulate.
Though his appeal was dismissed by the Supreme Court, the Court took up his case again and Medellin (D) argument rested in part on a holding by the International Court of Justice in Case Concerning Avena and Other Mexican Nationals (Mex v U.S.), 2004 I.C.J. 12 that the U.S. had violated the Vienna Convention rights of 51 Mexican national (including Medellin (D) and that their state-court convictions must be reconsidered, regardless of any forfeiture of the right to raise the Vienna Convention claims because of a failure to follow state rules governing criminal convictions.
Based on these, Medellin (D) argued that the Vienna Convention granted him an individual right that state courts must respect. A memorandum from the U.S. President that instructed state courts to comply with the I.C.J’s rulings by rehearsing the cases was also cited by Medellin (D). He further argued that the Constitution gives the President broad power to ensure that treaties are enforced, and that this power extends to the treatment of treaties in state court proceedings.
Issue. Are state courts required under the U.S. Constitution to honor a treaty obligation of the United States by enforcing a decision of the International Court of Justice?
(2) Are states courts required by the U.S. Constitution to provide review and reconsideration of a conviction without regard to state procedural default rules as required by a memorandum by the President?