In 2017, the United States District Court for the Eastern District of Pennsylvania denied the defendant’s petition for a writ of habeas corpus as to the guilt phase of his state criminal trial but granted relief with respect to his death sentence and remanded the case for resentencing. The District Court granted this relief only because the parties agreed to it. On remand in Commonwealth v. Speight, the sentencing court took the position that the federal District Court lacked authority to grant relief based exclusively on the parties’ agreement in the absence of an independent judicial determination consistent with 28 U.S.C. § 2254(d). The Pennsylvania Supreme Court reversed the sentencing court and remanded, holding that the District Court vacated the defendant’s death sentence as a matter of federal law, as mandated by Section 2254(d).
