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Abstract
| Argument: |
Tuesday, February 24, 1976
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| Decision: |
Tuesday, July 6, 1976 |
| Issues: |
Criminal Procedure, Habeas Corpus |
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Advocates
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Facts of the Case
Lloyd Powell was convicted of murder by a California court. Powell sought relief in federal district court by filing a writ of federal habeas corpus. Powell claimed that the search that uncovered the murder weapon was unlawful and that the evidence should have been inadmissible at trial. This case was decided together with Wolf v. Rice.
Question
Were federal courts obligated to consider claims of illegal searches and seizures after such claims had been decided by state courts?
Conclusion
In a 6-to-3 decision, the Court held that where states had provided opportunities for full and fair litigation of Fourth Amendment claims, the Constitution did not require the granting of federal habeas corpus relief. The Court also held that any additional benefits from considering search and seizure claims of state prisoners on collateral review would be small in relation to the costs. The Court found that the Fourth Amendment values protected by the exclusionary rule would not be significantly enhanced in such situations and that deterrence of police misconduct was unlikely to increase.