MURPHY, JEDIDIAH MURPHY v. the State of Texas

CourtCourt of Criminal Appeals of Texas
DecidedOctober 9, 2023
DocketAP-77,116
StatusPublished

This text of MURPHY, JEDIDIAH MURPHY v. the State of Texas (MURPHY, JEDIDIAH MURPHY v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Criminal Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MURPHY, JEDIDIAH MURPHY v. the State of Texas, (Tex. 2023).

Opinion

IN THE COURT OF CRIMINAL APPEALS OF TEXAS NO. AP-77,116

EX PARTE JEDIDIAH ISAAC MURPHY, Applicant

ON DIRECT APPEAL FROM DENIAL OF WRIT OF HABEAS CORPUS UNDER ARTICLE I, § 12 OF THE TEXAS CONSTITUTION AND TEXAS CODE OF CRIMINAL PROCEDURE 11.05 IN CAUSE NO. W00-02424-M(D) FROM THE 194TH JUDICIAL DISTRICT COURT DALLAS COUNTY

Per curiam. YEARY, J., filed a dissenting opinion. NEWELL and WALKER, JJ., dissented.

OPINION

Applicant appeals from a trial court order denying relief on the claims raised in his

Application for Writ of Habeas Corpus Under Article I, § 12 of the Texas Constitution

and Texas Code of Criminal Procedure Article 11.05.1 Applicant raises four points of

error. After reviewing the issues, we find the points to be without merit. Consequently,

we affirm the trial court’s order denying relief.

1 References to Articles in this opinion are to the Texas Code of Criminal Procedure unless otherwise specified. Murphy - 2

I. Background

Applicant was convicted and sentenced to death in June 2001 for the capital

murder of 80-year-old Bertie Cunningham. See TEX. PENAL CODE §19.03(a). The

evidence showed that on October 4, 2000, Cunningham went shopping at a mall in Plano,

Texas. She was returning to her Garland home when Applicant forced her at gunpoint to

give him a ride. Ultimately, Applicant forced Cunningham into the trunk of her car and

shot her. Applicant then drove Cunningham’s car around and used her credit cards to buy

alcohol and beer, among other things. At some point, he picked up his niece and two of

her school-age friends. He later dropped off his niece, and he and the boys continued

driving around. Ultimately, he bought them both motorized scooters before taking them

home. He eventually removed Cunningham from the trunk and dumped her in a creek.

This Court affirmed the judgment and sentence on direct appeal. Murphy v. State,

112 S.W.3d 592 (Tex. Crim. App. 2003). This Court also denied relief on the claims

raised in Applicant’s initial habeas application and dismissed his subsequent applications

as abuses of the writ. Ex parte Murphy, No. WR-70,832-01 (Tex. Crim. App. Mar. 25,

2009) (not designated for publication); Ex parte Murphy, No. WR-70,832-02 (Tex. Crim.

App. Mar. 21, 2012) (not designated for publication); Ex parte Murphy, No. WR-70,832-

05 (Tex. Crim. App. Oct. 4, 2023) (not designated for publication).

II. The Original Writ Application Filed in the Trial Court

In the original application filed in the trial court, Applicant raised several claims Murphy - 3

for relief in which he asserted that the Texas Department of Criminal Justice’s (TDCJ’s)

procurement, possession, distribution, and administration of drugs used for executions

violated both constitutional and statutory requirements. He asserted that the trial court

should give him relief so that he would not be made to suffer cruel and unusual

punishment in violation of the Constitution.

III. The Trial Court’s Ruling

The trial court noted the Glossip ruling from the United States Supreme Court in

which that Court held “that prisoners cannot successfully challenge a method of execution

unless they establish that the method presents a risk that is ‘sure or very likely to cause

serious illness and needless suffering,’ and give rise to ‘sufficiently imminent dangers.’”

Glossip v. Gross, 576 U.S. 863, 877 (2015). The court concluded that Applicant failed to

meet the threshold for relief.

IV. Applicant’s Arguments on Appeal and the Court’s Analysis

In his first point of error, Applicant complains that the trial court erred in denying

the writ without first affording him an evidentiary hearing. Applicant acknowledges that

there is generally no right to a hearing on a writ of habeas corpus. However, he asserts

that a hearing was necessary in this case because it “was the only way that [he] could

obtain the evidence to prove his claims.”

Applicant’s conclusory statements that a hearing was the only way to obtain

discovery does not make the statements true. Without more, Applicant has failed to show Murphy - 4

that the trial court abused its discretion in failing to hold a hearing. Applicant’s first point

of error is overruled.

In his second point of error, Applicant asserts that the trial court “failed to address

all of the claims [he] raised in arguing that his execution with fire-blighted expired drugs

violates the law.” To begin with, this claim assumes unproven “facts.” Throughout

Applicant’s pleadings, he asserts “facts” “on information and belief.” But he has not

shown that either “fire-blighted” or “expired” drugs will be used on him in his execution.

Recently addressing claims substantially similar to those raised in Applicant’s state

habeas application, the federal district court noted that a laboratory report dated nearly a

month after the fire showed two lots of pentobarbital that passed potency and sterility

tests. The court stated,

While it is unclear from the record whether this report encompasses all of the pentobarbital currently in TDCJ’s possession [or] if the drugs tested are the ones to be used in [Applicant’s] execution, it does undermine [Applicant’s] argument that all of TDCJ’s pentobarbital was damaged in the Huntsville fire. As a result, [Applicant’s] claim that the so-called “fire- blighted” pentobarbital is sure or very-likely to cause serious illness or suffering is meritless.

Murphy v. Lumpkin, No. 1:23-cv-01199-RP-SH, ECF 9 at *5 (W.D. Tex. Oct. 6, 2023).

That same report is currently in the record before this Court.

Returning to Applicant’s assertion that the trial court failed to address all of his

claims, we note that the trial court observed that Applicant had raised several grounds. It

subsequently held, “Applicant’s claims fail to meet the threshold for relief.” By all Murphy - 5

indications, the trial court ruled on all of Applicant’s claims. The court is not required to

explicitly and separately set out its reasoning on every argument made, and Applicant has

failed to show this Court exactly what claims he believes the trial court failed to address.

Without more, Applicant’s second point of error is overruled.

Applicant complains in his third point of error that the trial court erred in denying

the writ “because attempting to execute [Applicant] with fire-blighted, expired

pentobarbital violates the United States Constitution.” Again, Applicant’s claim assumes

unproven “facts.” Although Applicant “on information and belief” asserts his manner of

execution will be unconstitutional, he presents no evidence to support it. Additionally, as

the trial court pointed out, the U.S. Supreme Court adopted a two-element showing in

order to raise a method-of-execution claim. First, the defendant must show that the

method to be used “presents a risk that is ‘sure or very likely to cause serious illness and

needless suffering,’ and give rise to ‘sufficiently imminent dangers,’” and second, the

defendant “must identify an alternative [execution method] that is ‘feasible, readily

implemented, and in fact significantly reduce[s] a substantial risk of severe pain.’”

Glossip, 576 U.S. at 877. Applicant failed to make this showing. Point of error three is

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Related

City of Cleburne v. Cleburne Living Center, Inc.
473 U.S. 432 (Supreme Court, 1985)
Murphy v. State
112 S.W.3d 592 (Court of Criminal Appeals of Texas, 2003)
Glossip v. Gross
576 U.S. 863 (Supreme Court, 2015)

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