Must Directives of a Federal Court Be Obeyed Even If They Are Erroneous ?
In Madej v. Briley, 371 F.3d 898 (7th Cir. 2004), a federal district court issued a writ of habeas corpus ordering the State to provide the defendant with a new sentencing hearing because of his trial counsel's ineffectiveness. Madej, 371 F.3d at 898.
Per the district court's order, the State was to provide this hearing within 60 days of the order. Madej, 371 F.3d at 899.
After this deadline had passed, but before any hearing was held, then-Governor Ryan commutated the defendant's death sentence to natural life imprisonment. Madej, 371 F.3d at 899.
Following this commutation order, the State moved the district court to vacate its order as moot. Madej, 371 F.3d at 899.
The district court declined, noting that at a new hearing the defendant would be entitled to seek a term lower than the natural life sentence substituted by the Governor. Madej, 371 F.3d at 899.
The Seventh Circuit affirmed, finding it irrelevant that "the State believed the order of the district court ineffectual" following the Governor's commutation of the defendant's sentence. Madej, 371 F.3d at 899-900.
The court noted that "even erroneous directives of a federal court must be obeyed while they are outstanding." Madej, 371 F.3d at 900, citing Pasadena City Board of Education v. Spangler, 427 U.S. 424, 439-40, 49 L. Ed. 2d 599, 610, 96 S. Ct. 2697, 2706 (1976), quoting Howat v. Kansas, 258 U.S. 181, 190, 66 L. Ed. 2d 550, 559 42 S. Ct. 277, 281 (1922) ("It is for the court of first instance to determine the question of validity of the law, and until its decision is reversed for error by orderly review, either by itself or by a higher court, its orders based on its decision are to be respected, and disobedience of them is contempt of its lawful authority, to be punished").
The Seventh Circuit's decision in Madej concerns the respect that parties must accord judicial orders. Madej's holding springs from the State's alleged "obduracy" in ignoring a validly issued order by the district court and stands for the principle that no party may intentionally disregard such an order simply because it believes that order is erroneous. See Madej, 371 F.3d at 899-900.