Case Explained: CHARLES RIENHARDT V. RYAN THORNELL

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-15 Docket: 4:03-CV- The Ninth Circuit affirmed the district court’s denial of Charles Rienhardt’s habeas corpus petition challenging his Arizona conviction and death sentence for first-degree murder, kidnapping, attempted drug transfer, and attempted arson. The panel held that Rienhardt was not entitled to relief under the Antiterrorism and Effective Death Penalty Act (AEDPA) or the Sixth Amendment right to effective assistance of counsel. The court applied the deferential standards of *Strickland v. Washington* for ineffective-assistance-of-counsel claims and 28 U.S.C. § 2254(d)(1), which requires showing that the state court’s decision was contrary to or an unreasonable application of clearly established federal law. Regarding evidentiary development, the panel applied 28 U.S.C. § 2254(e)(2) and *Shinn v. Ramirez*, holding that Rienhardt failed to develop the factual basis of his claims in state court proceedings and therefore could not introduce new evidence or obtain an evidentiary hearing in federal court. The court rejected Rienhardt’s three certified ineffective-assistance claims: 1. **Attorney-as-Witness Claim:** The panel held that the state court’s rejection of the claim regarding trial counsel Eric Larsen’s potential conflict of interest was not unreasonable under *Cuyler v. Sullivan* or *United States v. Cronic*. Furthermore, Rienhardt could not establish prejudice because he failed to show a reasonable probability that a mistrial would have been granted or that the outcome would have changed given the overwhelming evidence against him. 2. **Attorney-Romance Claim:** The panel affirmed that this claim was procedurally defaulted because it was not raised in state court. Rienhardt could not establish “cause” to excuse the default under *Martinez v. Ryan* because doing so would require relying on new evidence developed after his initial post-conviction proceedings, which is barred by *Shinn*. 3. **Mitigation Claim:** The panel held that exhausted subclaims failed on the merits because Rienhardt explicitly waived mitigation at sentencing, precluding a showing of prejudice under *Schriro v. Landrigan*. Procedurally defaulted subclaims regarding the failure to file a sentencing memorandum or seek neuropsychological testing were also rejected due to lack of supporting evidence in the state record and reliance on post-proceeding evidence that could not be considered under *Shinn*. Finally, the court declined to expand the certificate of appealability to cover two uncertified claims: one regarding the admission of Larsen’s interview with a witness (Evidence Claim) and another regarding the Arizona Supreme Court’s requirement of a causal nexus between the crime and mitigation factors (Causal-Nexus Claim). The panel found these issues were not debatable among jurists of reason. The practical consequence is that Rienhardt’s conviction and death sentence remain in effect, and his federal habeas petition is fully denied with no further appellate review on the uncertified claims. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.