BALDWIN v. REESE

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Case Basics
Docket No. 
02-964
Petitioner 
George H. Baldwin
Respondent 
Michael Reese
Opinion 
Advocates
(argued the cause for Respondent)
(argued the cause for Petitioner)
Tags
Term:
Facts of the Case 

A state trial court sentenced Reese to 33 years in prison. An appellate court lowered the sentence to 24 years. In another appeal to a state appellate court, Reese argued his federal Sixth Amendment right to effective counsel was violated at trial and on appeal. The appellate court refused to reverse Reese's sentence. Reese appealed to the state supreme court and failed.

Reese appealed to a U.S. District Court. Ruling against Reese, the Court held that Reese did clearly say to the state supreme court his claims were federal. Federal law requires state prisoners to "fairly present" federal constitutional claims in each state court before appealing to federal courts. A federal appellate court reversed, ruling that the state supreme court had had the opportunity to read the state appellate court decision - had the court done this, it would have understood Reese's claims were federal.

Question 

Federal law requires state prisoners to "fairly present" their allegations of federal constitutional violations to state courts before turning to federal courts. To meet this requirement, do prisoners need to specifically say their claims are federal constitutional claims?

Conclusion 
Decision: 8 votes for Baldwin, 1 vote(s) against
Legal provision: 28 USC 2241-2255 (habeas corpus)

Yes. In an 8-1 opinion delivered by Justice Stephen Breyer, the Court held that Reese did not "fairly present" his Sixth Amendment ineffective counsel claim to state courts. Federal law thus barred Reese from turning to federal courts. The state court could have understood Reese's claims were federal if the court had read the lower court opinion. However, a state prisoner does not "fairly present" a federal claim to a state court if that court must read beyond what the prisoner files. There is no federal requirement that courts read lower court opinions.

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BALDWIN v. REESE. The Oyez Project at IIT Chicago-Kent College of Law. 19 June 2014. <http://www.oyez.org/cases/2000-2009/2003/2003_02_964>.
BALDWIN v. REESE, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2003/2003_02_964 (last visited June 19, 2014).
"BALDWIN v. REESE," The Oyez Project at IIT Chicago-Kent College of Law, accessed June 19, 2014, http://www.oyez.org/cases/2000-2009/2003/2003_02_964.