Ronald L. Sanders v. Jeanne S. Woodford, Warden, of California State Prison at San Quentin

Convicted of murder and sentenced to death, Ronald Sanders appeals the district court’s denial of his federal habeas petition, challenging both his conviction and his death sentence. We hold that the district court correctly rejected Sanders’ claim that the jury that convicted him was drawn from a jury venire that unconstitutionally failed to reflect the number of Hispanics in Kern County, where he was tried. We conclude, however, that Sanders did not receive an individualized death sentence, as required by the Eighth Amendment. The California Supreme Court neither independently reweighed aggravating and mitigating sentencing factors after it had invalidated two of the aggravating factors, nor did it conduct an appropriate harmless-error analysis. We also conclude that this error was not harmless. We therefore reverse the district court’s denial of Sanders’ habeas petition as it relates to the imposition of the death penalty and remand with instructions to grant the petition if the state does not either provide a new penalty trial or replace the sentence of death with another legally appropriate punishment.

FACTUAL AND PROCEDURAL BACKGROUND

Sanders was found guilty of murdering…