Golden Gate University Law Review Volume 23 Article 15 Issue 1 Ninth Circuit Survey January 1993 Criminal Procedure - The Robert Alton Harris Decision: Federalism, Comity, and Judicial Civil Disobedience Deirdre J. Cox Follow this and additional works at: http://digitalcommons.law.ggu.edu/ggulrev Part of the Criminal Law Commons Recommended Citation Deirdre J. Cox, Criminal Procedure - The Robert Alton Harris Decision: Federalism, Comity, and Judicial Civil Disobedience, 23 Golden Gate U. L. Rev. (1993). http://digitalcommons.law.ggu.edu/ggulrev/vol23/iss1/15 This Note is brought to you for free and open access by the Academic Journals at GGU Law Digital Commons. It has been accepted for inclusion in Golden Gate University Law Review by an authorized administrator of GGU Law Digital Commons. For more information, please contact
[email protected]. Cox: Criminal Procedure CRIMINAL PROCEDURE THE ROBERT ALTON HARRIS DECISION:l FEDERALISM, COMITY, AND JUDICIAL CIVIL DISOBEDIENCE I. INTRODUCTION On Tuesday, April 21, 1992, Robert Alton Harris became the first person to be executed in California in over 25 years. 2 It was perhaps predictable, therefore, that his execution was pre ceded by a flurry of legal activity.3 Last minute lawsuits pre empted a holiday weekend and extended into the early hours of the morning up until just 20 minutes before his 6:21 a.m. execu tion," The bulk of Harris' legal maneuvers encompassed a total of 16 habeas appeals over a 14 year period. II This article touches on only three of the many issues raised by the Harris case. 6 First, it explores the appropriateness of 1.