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Summary reversal decision announced in Allen v. Siebert
In a 7-2 decision released today, the United States Supreme Court has reinstated the death sentence of Alabama serial murderer Daniel Siebert.
Earlier this year, in the case of Siebert v. Allen, the Federal Eleventh Circuit Court of Appeals ruled that, after nearly two decades since his convictions for murdering a young mother, her two sons, and a neighbor, Siebert was entitled to additional consideration of claims filed well past deadlines set by both Alabama and federal law.
At the invitation of the Alabama Attorney General, the California-based Criminal Justice Legal Foundation joined the case to ask the Court to summarily reverse the lower court decision. CJLF argued that the Eleventh Circuit misinterpreted Supreme Court precedent regarding improperly filed claims.
The Court’s decision focused on this point, stating “We therefore reiterate now what we held in Pace: When a postconviction petition is untimely under state law, that is the end of the matter. . . .”
“Today’s decision is an appropriate rebuke of the Eleventh Circuit’s evasion of controlling precedent,” said Foundation Legal Director Kent Scheidegger.
According to court records, in 1985, Siebert had volunteered under an assumed name to teach art at the Alabama Institute for the Deaf and Blind in Talladega. He later expressed a romantic interest in one of the students, 24-year-old Sherri Weathers, a hearing-impaired single mom. On February 24, 1986, Sherri’s school counselor called her apartment manager to express concerns about her missing a week of classes. The manager used a pass key to enter Sherri’s apartment where she was found strangled to death along with her sons, five-year-old Chad and four-year-old Joseph. When the police arrived, the manager directed them to another apartment occupied by 33-year-old Linda Jarman, another student missing from the institute. Her nude, lifeless body was found on her bed.
At the time of these murders, Siebert, who had been convicted in Las Vegas of manslaughter in 1979, was also wanted in San Francisco on charges of first-degree assault. Detectives learned that he had been dating Linda Odum, a 32-year-old cocktail waitress reported missing the same day that the bodies of the murder victims were found. On March 3, Odum’s car, with Siebert’s fingerprints, was found abandoned in Kentucky. Her nude, decomposed body was found outside of Talladega on March 30. Investigators also uncovered evidence linking Siebert with the strangulation of a nearby Calhoun County prostitute around the time he disappeared.
After a six-month nationwide manhunt, police arrested Siebert at a Nashville restaurant where he was working as a handyman.
During police questioning, Siebert confessed to five murders in Alabama and “maybe a dozen” across the country. He admitted that he killed for the purposes of sex and robbery. In addition to the murders of Sherri Weathers, her sons, and Linda Jarman, Siebert was later charged with the 1985 murder of 28-year-old Gidget Castro and 23-year-old Nesia McElrath in Los Angeles, CA, and the 1986 strangulation of 57-year-old Beatrice McDougall in Atlantic City, NJ.
In April 1987, Siebert was sentenced to death for the Jarman murder and, four months later, given another death sentence for the Weathers’ murders. By May 22, 1990, both convictions and sentences had been upheld by the Alabama Supreme Court on direct appeal. Alabama law requires a defendant to file his state habeas corpus claims within two years of the final judgment of the Alabama Supreme Court.
On August 24, 1992, over three months past the deadline, Siebert filed petitions seeking state habeas corpus review of both convictions and sentences. The county circuit court rejected both petitions as untimely, and the state Supreme Court later affirmed that holding.
In 1996, the President signed the Antiterrorism and Effective Death Penalty Act (AEDPA) into law. The Act requires defendants to file their federal habeas corpus claims no later than one year after the state courts have reviewed and decided them. This time period is suspended while a “properly filed” petition is pending in state court.
In September 2001, Siebert filed petitions for habeas corpus review in the federal courts. These were dismissed for violation of the AEDPA time limit. In 2005, while Siebert’s appeal of the dismissal was pending in the Eleventh Circuit Court of Appeals, the U. S. Supreme Court decided in another case that state “time limits, no matter their form, are filing conditions,” and an untimely state petition does not suspend the federal limitations period. Two years later, a panel of the Eleventh Circuit ruled that Alabama’s time limits did not prevent federal court consideration of Siebert’s claims.
When the state of Alabama decided to appeal that ruling, CJLF was asked to file argument in support of the state’s petition for Supreme Court review. The Foundation’s amicus curiae (friend of the court) brief argued that “summary reversal is appropriate when the decision below is legally erroneous and the error is obvious,” and cites the Eleventh Circuit’s ruling as “demonstrably erroneous.” Today’s summary reversal overturned the lower court ruling without a hearing or additional argument.
The case decided today is for the murder of Ms. Jarman. Execution of Siebert’s death sentence for the Weathers murder was stayed by the Eleventh Circuit on October 25 while it considers his challenge to Alabama’s lethal injection procedure.