Michael Murdaugh v. Charles Ryan

Petitioner Michael Joe Murdaugh appeals the denial of his federal habeas petition, which challenges his murder conviction and death sentence. Murdaugh claims that the district court erred in denying claims brought pursuant to Ring v. Arizona, 586 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), and Tennard v. Dretke, 542 U.S. 274 , 124 S.Ct. 2562 , 159 L.Ed.2d 384 (2004), as well as claims raising other errors by the state court and the ineffective assistance of counsel. Murdaugh also argues that the district court erred in deeming various claims procedurally defaulted. We grant relief on Murdaugh’s Ring claim and reserve judgment on Murdaugh’s claims about his competence to waive the presentation of mitigating evidence. We otherwise affirm the district court.

I. Background

1. The Murders of David Reynolds and Douglas Eggert

On June 26,1995, Murdaugh’s girlfriend, Rebecca Rohrs, met David Reynolds at a gas station. She told him she was looking for a job, and they exchanged phone numbers. The conversation took a sordid turn when Reynolds offered to pay Rohrs to perform oral sex. Rohrs declined, returned home, and described the encounter to Murdaugh. Murdaugh decided…