The Oyez Project: Criminal Procedure Issues - Habeas Corpus Decisions

Abdur'Rahman v. Bell

Does a Federal Rule of Civil Procedure 60(b) motion, filed in a habeas corpus proceeding to inform the federal courts of a state court's interpretation of state procedural laws, constitute a "successive" habeas corpus petition?

In a per curiam opinion, the writ of certiorari was dismissed as improvidently granted. Justice John Paul Stevens dissented. Justice Stevens argued that the Court of Appeals plainly erred when it characterized Abdur'Rahman's Rule 60(b) motion as an application for a second or successive habeas petition and denied relief for that reason.

al Odah v. United States

Do United States courts have jurisdiction to consider legal appeals filed on behalf of foreign citizens held by the United States military in Guantanamo Bay Naval Base, Cuba?

Yes. In a 6-to-3 opinion written by Justice John Paul Stevens, the Court found that the degree of control exercised by the United States over the Guantanamo Bay base was sufficient to trigger the application of habeas corpus rights. Stevens, using a list of precedents stretching back to mid-17th Century English Common Law cases, found that the right to habeas corpus can be exercised in "all ... dominions under the sovereign's control." Because the United States exercised "complete jurisdiction and control" over the base, the fact that ultimate sovereignty remained with Cuba was irrelevant. Further, Stevens wrote that the right to habeas corpus is not dependent on citizenship status. The detainees were therefore free to bring suit challenging their detention as unconstitutional.

Amadeo v. Zant

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Artuz v. Bennett

Is an application for state postconviction relief containing procedurally barred claims properly filed within the meaning of the Antiterrorism and Effective Death Penalty Act of 1996?

Yes. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that an application for state postconviction relief containing procedurally barred claims is properly filed within the meaning of the Antiterrorism and Effective Death Penalty Act of 1996. Writing for the unanimous court, Justice Antonin Scalia said that "[o]nly individual claims, and not the application containing those claims, can be procedurally defaulted under state law." "An application is 'filed,' as that term is commonly understood, when it is delivered to, and accepted by, the appropriate court officer for placement into the official record," noted Justice Scalia. "By construing 'properly filed application' to mean 'application raising claims that are not mandatorily procedurally barred,' [the Federal Government] elides the difference between an 'application' and a 'claim,'" argued Justice Scalia.

Bell v. Cone

Does defense counsel render ineffective assistance during the sentencing phase of a murder trial by failing to present mitigating evidence and waiving final argument?

No. In an 8-1 opinion delivered by Chief Justice William H. Rehnquist, the Court held that Tennessee Court of Criminal Appeals's decision neither was "contrary to" nor involved "an unreasonable application of clearly established Federal law" under the provisions of 28 USC section 2254(d)(1). The Court noted that the defense counsel was defending a client who had committed a brutal and senseless crime against two elderly persons. Rather than closing, defense counsel prevented the lead prosecutor from arguing by waiving his own summation and relying on his opening plea for life. "Neither option, it seems to us, so clearly outweighs the other that it was objectively unreasonable for the Tennessee Court of Appeals to deem counsel's choice to waive argument a tactical decision about which competent lawyers might disagree," wrote Chief Justice Rehnquist. Justice John Paul Stevens dissented.

Boyd v. Dutton

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Braden v. 30Th Judicial Circuit Court Of Ky.

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Breard v. Greene

May Angel Francisco Breard, a Paraguayan citizen, and various Paraguayan diplomats receive a stay of execution and other relief, respectively, for the capital murder of Ruth Dickie under the Vienna Convention on Consular Relations?

No. In a per curiam opinion, the Court denied the stay applications and all other relief. The majority of the Court concluded that, because he had procedurally defaulted it, Breard could not raise his Vienna Convention claim on federal habeas corpus review. Moreover, the Court reasoned that Breard could not have demonstrated that the alleged violation of the Vienna Convention had an effect on his state trial that ought to have resulted in the overturning of his conviction. Additionally, the Court found that the Vienna Convention did not clearly provide a foreign nation with a private right of action in U.S. courts. Justices John Paul Stevens, Ruth Bader Ginsburg, and Stephen G. Breyer, in separate dissents, argued that the Court ought to have granted the stay applications and considered the merits of the case to different degrees.

Brecht v. Abrahamson

Is the "beyond a reasonable doubt" standard from Chapman v. California the appropriate standard for setting aside a conviction on the basis of constitutional error?

No. In a 5-4 decision, Chief Justice William H. Rehnquist wrote that the "substantial and injurious effect" test was preferable to the "beyond a reasonable doubt" test in requests for habeas corpus relief. Habeas proceedings are not to be the primary avenue for resolving disputes; Rehnquist called the writ "an extraordinary remedy", reserved for the victims of grave injustice. The Kotteakos standard, then, was sufficient to determine whether Brecht deserved habeas relief.

Butler v. McKellar

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Calderon v. Coleman

Did a court of appeals, in overturning a death sentence due to constitutional errors in the jury instruction, fail to adequately consider whether the errors were "harmless" and made a difference in the final result under Brecht v. Abrahamson?

Yes. In a 5-4 per curiam opinion, the Court held that "once the Court of Appeals determined that the giving of the Briggs instruction was constitutional error, it was bound to apply the harmless-error analysis mandated by Brecht." The Court held in Brecht that "a federal court may grant habeas relief based on trial error only when that error "'had substantial and injurious effect or influence in determining the jury's verdict.'" Dissenting, Justice John Paul Stevens wrote that "there might have been a slight flaw in the Court of Appeals' brief explanation of why the invalid instruction given to the jury was not harmless, but...the Court's ruling was unquestionably correct." Justices David H. Souter, Ruth Bader Ginsburg, and Stephen G. Breyer joined Justice Stevens' dissent.

Calderon v. Thompson

Did the Court of Appeal's order recalling its mandate denying Thomas M. Thompson all habeas relief violate 28 USC section 2244(b) as amended by the Antiterrorism and Effective Death Penalty Act of 1996? Was the order an abuse of the appellate court's discretion?

No and yes. In a 5-4 opinion delivered by Justice Anthony M. Kennedy, the Court held that although it was consistent with the Antiterrorism and Effective Death Penalty Act of 1996, the recall was a grave abuse of discretion. The Court established that "where a federal court of appeals sua sponte recalls its mandate to revisit the merits of an earlier decision denying habeas corpus relief to a state prisoner, the court abuses its discretion unless it acts to avoid a miscarriage of justice as defined by our habeas corpus jurisprudence." Accordingly, Justice Kennedy, noting that Thompson's evidence was not clear and convincing, concluded that California's judgment would not result in a miscarriage of justice. Justice David H. Souter wrote a dissenting opinion, in which Justices John Paul Stevens, Ruth Bader Ginsburg and Stephen G. Breyer joined.

California v. Roy

Did the Court of Appeals, in applying a special harmless-error standard, apply a too-strict harmless-error standard for the purposes of federal habeas corpus review of a California trial judge's error in instructing a jury as to the elements of the crime of first-degree murder?

Yes. In a per curiam opinion, the Court held that as a federal court reviewing a state-court determination in a habeas corpus proceeding, the Court of Appeals should have applied the harmless-error standard whether the error had substantial and injurious effect or influence in determining the jury's verdict. The Court reasoned that the error at issue, a misdescription of an element of the crime, was an error of omission and not an error of the structural sort in the trial mechanism that defies harmless-error analysis.

Carafas v. Lavallee

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Carbo v. United States

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Carey v. Saffold

Does the word "pending," in the Antiterrorism and Effective Death Penalty Act of 1996, cover the time between a lower state court's decision and the filing of a notice of appeal to a higher state court? If so, does it apply similarly to California's unique state collateral review system?

Yes and yes. In a 5-4 opinion delivered by Justice Stephen G. Breyer, the Court held that, as used in AEDPA, "pending" covers the time between a lower state court's decision and the filing of a notice of appeal to a higher state court. The Court also held that the same rule applies to California's unique collateral review system, a system that does not involve a notice of appeal, but rather the filing within a reasonable time of a further original state habeas petition in a higher court. The Court reasoned that to rule otherwise would encourage state prisoners to file federal habeas petitions before the state completed collateral review. In remanding the question of whether Saffold's petition was pending, the Court concluded that the California Supreme Court's inclusion of the words "on the merits" could not by themselves indicate that the petition was timely. Justice Anthony M. Kennedy authored a dissent, in which Chief Justice William H. Rehnquist and Justices Antonin Scalia and Clarence Thomas joined.

Caspari, Superintendent, Missouri Eastern Correctional Center v. Bohlen

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Castille v. Peoples

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Castro v. United States

When a district judge re-classifies a post-conviction motion by a defendant, turning it into a petition for a writ of habeas corpus, does that preclude future petitions for a writ of habeas corpus under the Antiterrorism and Effective Death Penalty Act of 1996?

In a unanimous opinion delivered by Justice Stephen Breyer, the Court held that a federal court can recharacterize a motion as a first habeas corpus petition only if the court: (1) informs the litigant of the court's intent to recharacterize; (2) warns the litigant that this recharacterization means that any subsequent habeas corpus petition will be treated as a second petition; (3) gives the litigant an opportunity to withdraw or amend the motion. The Court held that because the district court failed to give these prescribed warnings, Castro's 1994 motion could not be considered a first habeas corpus petition and his 1997 motion therefore could not be considered a second petition.

Clay v. United States

Does a judgment become "final" for postconviction relief when the appellate court issues its mandate affirming the conviction where a defendant in a federal prosecution takes an unsuccessful direct appeal from a judgment of conviction but does not next petition for a writ of certiorari from the U.S. Supreme Court?

No. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that, for the purpose of starting the clock on section 2255's one-year limitation period, a judgment of conviction becomes final when the time expires for filing a petition for certiorari contesting the appellate court's affirmation of the conviction. Under this rule, Clay's section 2255 motion was timely filed. After comparing the understanding of finality for collateral review purposes to the meaning of the phrase "becomes final" in 28 USC section 2255, the Court rejected the standard that the issuance of the appellate court mandate is the triggering date.

Coleman v. Thompson

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Davis v. United States

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Day v. McDonough

May a court dismiss a federal habeas petition as untimely, even after the state concedes the timeliness of the petition and submits other arguments?

Yes. In a 6-3 decision, the Court affirmed the judgment of the Circuit Court and ruled that the District Court was within its discretion when it dismissed Day's petition. The opinion by Justice Ruth Bader Ginsburg held that "if a judge does detect a clear computation error, no Rule, statute, or constitutional provision commands the judge to suppress that knowledge." The majority held that federal courts are not obligated to dismiss petitions for untimeliness if the state does not raise the issue, but they may as long as they give the petitioner notice and an opportunity to dispute the timeliness. Justice Stevens joined the Court's opinion but dissented from the judgment. Justice Scalia wrote a separate dissent joined by Justices Thomas and Breyer.

Dodd v. United States

Is the start date for a federal prisoner's one-year limitation period the date on which the Court "initially recongized" the right asserted in an applicant's motion, or the date on which the right is "made retroactive?"

In a 5-4 opinion delivered by Justice Sandra Day O'Connor, the Court held that the text of the federal law "unequivocally" stated that the one-year limitation period begins to run on the date on which the Court "initially recongized" the right, not the date on which that right was made retroactive. O'Connor wrote that Dodd's reliance on the statute's second clause was misplaced, because that clause merely limited the subsection's applicability to cases where applicants assert rights both "newly recognized by the Supreme Court and made applicable to cases on collateral reviiew." Thus, the date the right was asserted does not apply at all unless the second clause's conditions are met. The Court noted that this would make it difficult for applicants filing second or successive motions to obtain relief, since the Court rarely announces a new rule and makes it retroactive within a year.

Dretke v. Haley

Does the actual-innocence exception to the procedural-default doctrine apply to both capital and non-capital cases?

The Court declined to answer the question presented, ruling instead that the district court should have first considered the ineffective assistance of counsel claim before reaching the question of whether the "actual innocence" exception applies to non-capital cases. Justice Sandra Day O'Connor, for a seven-member majority, wrote that the ineffective assistance of counsel claim would accomplish the same thing - the reduction of the sentence - without burdening the state with the need to prove the existence of all prior convictions beyond a reasonable doubt.

Dugger v. Adams

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Duncan v. Walker

Is a federal habeas corpus petition is an "application for State post-conviction or other collateral review" within the meaning of 28 USC section 2244(d)(2), such that the one-year statute-of-limitations period under the Antiterrorism and Effective Death Penalty Act is tolled?

No. In a 7-2 opinion delivered by Justice Sandra Day O'Connor, the Court held that an federal habeas corpus petition is not an "application for State post-conviction or other collateral review" within the meaning of 28 USC section 2244(d)(2). "Section 2244(d)(2) therefore did not toll the limitation period during the pendency of [Walker's] first federal habeas petition," wrote Justice O'Connor. "[I]f the statute were construed so as to give applications for federal review the same tolling effect as applications for state collateral review, then [section] 2244(d)(2) would furnish little incentive for individuals to seek relief from the state courts before filing federal habeas petitions," concluded Justice O'Connor.

Edwards v. Carpenter

May a state prisoner's procedurally defaulted claim of ineffective assistance of counsel excuse the procedural default of another habeas corpus claim?

No. In a opinion delivered by Justice Antonin Scalia, the Court held that a state prisoner's procedurally defaulted claim of ineffective assistance of counsel can excuse the procedural default of another habeas claim only if the inmate can demonstrate that the poor lawyering rises to a constitutional level, not only that it prejudiced them at trial. The 7-2 decision means that ineffective-assistance claims filed too late in a state appellate court generally cannot be used in federal court to excuse an inmate's default on other claims. Justice Scalia wrote for the court that it is not enough to say such a claim "was presented to the state courts even though it was not presented in the manner that state law requires."

Engle v. Isaac

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Evans v. Chavis

When a state court denies a habeas petition summarily, without explanation, does the time that a defendant spent filing that petition count toward the one-year statute of limitations in federal habeas appeals under the Antiterrorism and Effective Death Penalty Act?

Yes. In a unanimous decision written by Justice Stephen Breyer, the Court held that the California Supreme Court's summary denial was not necessarily an indication that the petition was timely under state law. The petition was in fact untimely because the three-year delay could not be considered a "reasonable time," which is the timeliness standard for filing a petition under California law. If the state petition was untimely, it could not be considered "pending" between the time of the lower court's denial and the filing of the state habeas petition. Therefore, the Court held that the three-year filing delay did count towards the AEDPA's one-year limitation, meaning the federal habeas petition was also untimely.

Fay v. Noia

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Felker v. Turpin

Do the Act's Title I provisions, preventing the Supreme Court from reviewing an appellate review panel's denial of leave to file a second habeas petition, unconstitutionally "suspend" the habeas writ and restrict the Court's authority to entertain original habeas petitions?

No. The unanimous Court held that the Act's creation of an appellate panel, charged with reviewing all second or successive habeas applications, is not unconstitutional. The Act simply transfers the duty of habeas review from the district courts to an appellate panel. While the Act prevents an appeal to the Court from an appellate panel's denial of leave to file a second habeas petition, it does not repeal the Court's authority to entertain original habeas petitions. Thus, the shift in habeas "gatekeeping" duties to an appellate panel is neither an unconstitutional "suspension" of the habeas writ which would violate the Exceptions Clause of Article III, nor a deprivation of the Court's appellate jurisdiction.

Francis v. Henderson

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Francisco v. Gathright

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Garlotte v. Fordice, Governor Of Mississippi

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Gilmore v. Taylor

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Graham v. Collins, Director, Texas Department Of Criminal Justice, Institutional Division

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Gray v. Netherland, Warden

Can a defendant sentenced to death argue in his habeas corpus petition that prosecutors deceived him, in violation of the Fourteenth Amendment Due Process Clause, by producing surprise evidence in the sentencing phase of the trial?

No. In a 5-4 decision, announced by Chief Justice William H. Rehnquist, the Court ruled that the notice-of-evidence claim would require the adoption of a new constitutional rule and therefore could not be raised in a habeas petition. In her dissent, Justice Ruth Bader maintained that due process allows Gray the right to a "full, fair, potentially effective opportunity to defend against the State's charges." Gary was not given that right.

Hamdan v. Rumsfeld

May the rights protected by the Geneva Convention be enforced in federal court through habeas corpus petitions? Was the military commission established to try Hamdan and others for alleged war crimes in the War on Terror authorized by the Congress or the inherent powers of the President?

Yes and no. The Supreme Court, in a 5-to-3 decision authored by Justice John Paul Stevens, held that neither an act of Congress nor the inherent powers of the Executive laid out in the Constitution expressly authorized the sort of military commission at issue in this case. Absent that express authorization, the commission had to comply with the ordinary laws of the United States and the laws of war. The Geneva Convention, as a part of the ordinary laws of war, could therefore be enforced by the Supreme Court, along with the statutory Uniform Code of Military Justice. Hamdan's exclusion from certain parts of his trial deemed classified by the military commission violated both of these, and the trial was therefore illegal. Justices Scalia, Thomas, and Alito dissented. Chief Justice John Roberts, who participated in the case while serving on the DC Circuit Court of Appeals, did not take part in the decision.

Harris v. Reed

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Hensley v. Municipal Court

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Herrera v. Collins, Director, Texas Department Of Criminal Justice, Institutional Division

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Hilton v. Braunskill

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Hodges v. United States

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Horn v. Banks

Did the Court of Appeals err by failing to perform an analysis of whether Mills v. Maryland, 486 U.S. 367, applied retroactively to cases on federal habeas corpus review under Teague v. Lane, 489 U.S. 288?

Yes. In a per curiam opinion, the Court held that the Court of Appeals committed a clear error by failing to perform a Teague analysis. The Court reasoned that, since the officials raised the retroactivity issue in both the district court and the appellate court, it was clear error for the appellate court to refuse to determine the retroactive applicability of the new case law, even though the highest state court did not consider the issue in determining the inmate's direct appeal. The Court concluded that the retroactivity question was a threshold issue which required resolution prior to any consideration of the merits of Banks' claims.

House v. Bell

Did the federal appeals court err in applying Schlup v. Delo to hold that House's new evidence, though presenting at the very least an arguable claim of innocence, was legally insufficient to excuse his failure to present that evidence in state court? What constitutes a "truly persuasive showing of actual innocence" under Herrera v. Collins, sufficient to warrant freestanding habeas relief?

Yes, and unanswered. In a 5-3 decision, the Court ruled that the Court of Appeals was wrong to deny House's habeas petition. The opinion by Justice Anthony Kennedy held that though the standard in Schlup v. Delo was "demanding," House's case was so extraordinary that it could be granted review despite his failure to present his new evidence in state court. This was because House's new evidence, while not necessarily proving his innocence, was sufficiently compelling that no reasonable juror would have found him guilty beyond a reasonable doubt. Accordingly, the Court sent the case back to the lower courts with instructions to hear House's new claims.

The Justices declined to clarify the "persuasive demonstration of actual innocence" standard in Herrera v. Collins, except to note that since House's evidence just barely met the high standard in Schlup, it did not meet the "extraordinarily high" threshold in Herrera.

Chief Justice John Roberts wrote a dissenting opinion, which was joined by Justices Scalia and Thomas. The dissent argued that under Schlup it was not enough for new evidence to cast doubt on House's conviction; the totality of the evidence had to prove "that House was actually innocent." The dissenters also stressed that the Court should defer to the District Court and not simply take the new evidence "at face value." Justice Alito took no part in the decision of this case.

Humphrey v. Cady

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Jackson v. Virginia

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Jones v. Cunningham

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Kaufman v. United States

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Keeney, Superintendent, Oregon State Penitentiary v. Tamayo-Reyes

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Lambrix v. Singletary

Can a Florida killer's death sentence be challenged even though it was based on aggravating factors later ruled to be unconstitutional?

No. In a 5-4 decision, authored by Justice Antonin Scalia, the Court ruled that a prisoner whose conviction became final before the ruling, which held that if the sentencing judge in a "weighing" State is required to give deference to a jury's advisory sentencing recommendation, then neither the jury nor the judge is constitutionally permitted to weigh invalid aggravating circumstances, is foreclosed from relying on that decision in a federal habeas corpus proceeding. Justice Scalia wrote for the court that the later ruling announced a "new rule" that could not be applied to already-finalized convictions challenged in federal habeas corpus petitions.

Lefkowitz v. Newsome

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Lehman v. Lycoming County Children's Services

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Lindh v. Murphy

Does the Antiterrorism and Effective Death Penalty Act of 1996, which amended the previous federal habeas statute, govern habeas applications in non-capital cases that were pending when the Act was enacted?

No. In a 5-4 opinion delivered by Justice David H. Souter, the Court held that the 1996 version of the federal habeas statute, as to standards affecting the entitlement of state prisoners to federal habeas corpus relief, does not to apply to non-capital habeas corpus cases that were pending when the Act was enacted. The Court reasoned that the statute's retroactive application was improper because new legal consequences attached. Chief Justice William H. Rehnquist wrote a dissenting opinion, in which Justices Antonin Scalia, Anthony M. Kennedy and Clarence Thomas joined.

Lockyer v. Andrade

Did the Federal Court of Appeals err in holding that California Court of Appeal's affirmation of a sentence of two consecutive terms of 25 years to life in prison for a "third strike" conviction was "grossly disproportionate" to the crime and thus violated the Eighth Amendment's prohibition on "cruel and unusual punishment"?

Yes. In a 5-4 opinion delivered by Justice Sandra Day O'Connor, the Court held that the Court of Appeals erred in ruling that the California Court of Appeal's decision was contrary to, or an unreasonable application of, the Court's clearly established law within the meaning of 28 USC section 2254(d)(1). The Court reasoned that, because the "precise contours" of the proportionality principle were unclear, it was not objectively unreasonable for the state appellate court to conclude that the "contours" permitted an affirmance of the sentence. The gross disproportionality principle reserves a constitutional violation for only the extraordinary case, wrote Justice O'Connor. "This is the rare sentence of demonstrable gross disproportionality," argued Justice David H. Souter in his dissent, in which Justices John Paul Stevens, Ruth Bader Ginsburg, and Stephen G. Breyer joined.

Lonchar v. Thomas

May a federal court dismiss a first federal habeas petition for general "equitable" reasons beyond those embodied in the federal Habeas Corpus Rules?

No. In an opinion authored by Justice Stephen G. Breyer, the Court held that federal Habeas Corpus Rule 9, not some general "equitable" power to create exceptions to the Rule, should have determined whether or not a petition's dismissal was appropriate. Justice Breyer wrote for the court that a long delay does not generally constitute an abuse of the system, adding, "[d]ismissal of a first habeas petition is a particularly serious matter for that dismissal denies the petitioner the protections of the Great Writ entirely."

Maleng v. Cook

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Massaro v. United States

Must claims of ineffective assistance of counsel, whether or not there is new counsel on appeal and whether or not the basis for the claim is apparent from the trial record, be raised on direct appeal?

No. In a unanimous opinion delivered by Justice Anthony M. Kennedy, the Court held that failure to raise an ineffective-assistance-of-counsel claim on direct appeal does not bar the claim from being brought in a collateral proceeding under section 2255, whether or not the petitioner could have raised the claim on direct appeal. The Court reasoned that requiring a criminal defendant to bring ineffective-assistance claims on direct appeal would create a risk that defendants would feel compelled to raise the issue before there has been an opportunity fully to develop it. Moreover, the Court noted its new rule would provide for ineffective-assistance claims to be litigated in the District Court, the forum best suited to developing the facts necessary to determining the adequacy of representation during an entire trial.

Mayle v. Felix

Federal habeas law allowed an amended petition to relate back to the filing date of the original petition if both arose out out of the same "conduct, transaction or occurrence" the original set forth. Did the trial and conviction qualify as a "conduct, transaction or occurrence?"

No. In a 7-2 opinion delivered by Justice Ruth Bader Ginsburg, the Court rejected the argument that the trial itself was the "transaction" or "occurrence" under federal habeas law. The Court said that such a definition would have allowed virtually any new claim introduced in an amended petition to relate back, gutting the one-year time limit on petitions. Felix's amended habeas petition thus did not relate back because the issue of his pretrial statements differed in time and type from the videotaped witness testimony.

Mccleskey v. Zant

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Mcfarland v. Scott, Director, Texas Department Of Criminal Justice, Institutional Division

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Miller v. Fenton

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Miller-El v. Cockrell

Must an inmate demonstrate that a state court's finding of the absence of purposeful discrimination was incorrect by clear and convincing evidence in order for a court of appeals to issue a certificate of appealability?

No. In an 8-1 opinion delivered by Justice Anthony M. Kennedy, the Court held that the Court of Appeals should have issued a COA to review the District Court's denial of habeas corpus relief. The Court reasoned, "when a habeas applicant seeks permission to initiate appellate review of the dismissal of his petition, the court of appeals should limit its examination to a threshold inquiry into the underlying merit of his claims." Thus, a prisoner seeking a COA need only demonstrate "a substantial showing of the denial of a constitutional right" and satisfies this standard by demonstrating that jurists of reason could disagree with the district court's resolution of his constitutional claims or that jurists could conclude the issues presented are adequate to proceed further. Justice Clarence Thomas dissented.

Miller-El v. Dretke

1. Did the Fifth Circuit Court of Appeals, by rejecting Miller-El's claim the prosecution purposefully excluded blacks from his jury, violate the U.S. Supreme Court's decision in Miller-El v. Cockrell (2003)? 2. Did the Texas jury selection manual encourage unconstitutional disparate questioning based on race?

Yes and yes. In a 6-3 opinion delivered by Justice David Souter, the Court held that Miller-El deserved to win his appeal because the jury selection in his case violated the Fourteenth Amendment's equal protection clause. The Court began by noting that the prosecutors used peremptory strikes to exclude 91 percent of the eligible black prospective jurors, "a disparity unlikely to have been produced by happenstance." After comparing two eliminated black prospective jurors with similar white jurors who were not eliminated, the Court concluded that the "selection process was replete with evidence that prosecutors were selecting and rejecting potential jurors because of race." The Court further concluded that Texas' jury selection manual, both in this case and generally, tended to allow prosecutors to read disparate questions to prospective jurors depending on whether they were black or white.

Mitchell v. Esparza

Did the Ohio Appeals Court violate "clearly established Federal law" by deciding that the prosecution's failure to charge Esparza as the "principle offender" in a murder was harmless and therefore not grounds for overturning his death sentence?

No. In a per curiam decision, the Supreme Court held that the Ohio Appeals Court had not acted unreasonably or violated "clearly established Federal law" when it decided that the prosecutor's error was harmless. The federal courts, therefore, did not have authority to overturn the death sentence.

Murray v. Carrier

Should a claim that would otherwise be prohibited by state court procedural rules barring claims not raised in an initial appeal be permitted if a defendant can prove that the omission was due entirely to an attorney's mistake (rather than to a tactical decision)?

No. In a decision authored by Justice Sandra Day O'Connor, the Supreme Court ruled that merely proving that an omission resulted from an attorney's mistake rather than from a tactical decision does not exempt a defendant from state court procedural rules. Justice O'Connor wrote, "We see little reason why counsel's failure to detect a colorable constitutional claim should be treated differently from a deliberate but equally prejudicial failure by counsel to raise such a claim. The fact that the latter error can be characterized as a misjudgment, while the former is more easily described as an oversight, is much too tenuous a distinction to justify a regime of evidentiary hearings into counsel's state of mind in failing to raise a claim on appeal."

Nelson v. George

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O'neal v. Mcaninch, Warden

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O'Sullivan v. Boerckel

Must a state prisoner present all of his claims to a state supreme court in a petition for discretionary review in order to satisfy the exhaustion requirement, 28 U. S. C. Sections 2254(b)(1), (c), for federal habeas relief?

Yes. In a 6-3 decision, delivered by Justice Sandra Day O'Connor, the Court held that in order to satisfy the exhaustion requirement, a state prisoner must present his claims to a state supreme court in a petition for discretionary review when that review is part of the State's ordinary appellate review procedure. Justice O'Connor wrote for the court that "state prisoners must give the state courts one full opportunity to resolve any constitutional issues by invoking one complete round of the state's established appellate review process." Inmates can use federal habeas petitions as shortcuts only if their state's highest court does not allow them to raise all claims before it, she said.

Peyton v. Rowe

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Picard v. Connor

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Pliler v. Ford

Is a judge required to warn a habeas corpus petitioner who is representing himself that his claims may be barred by a statute of limitations if he chooses to drop the claims and re-file them at a later date?

No. In an opinion by Justice Clarence Thomas, the Court ruled that a judge is not required to warn a habeas corpus petitioner who is representing himself of the consequences of his legal decision. Justice Thomas wrote, "District judges have no obligation to act as counsel or paralegal to pro se litigants." Five justices joined Thomas' opinion, while two others concurred in his judgment.

Preiser v. Rodriguez

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Price v. Vincent

Is a defendant's right against double jeopardy violated when a trial judge grants a motion for a directed verdict of acquittal as to first-degree murder, but does not direct such a verdict to the jury that subsequently convicts the defendant of first-degree murder?

No. In a unanimous opinion delivered by Chief Justice William H. Rehnquist, the Court held that the defendant did not meet the requirements for habeas relief. The Court stated that Vincent was entitled to relief only if he can demonstrate that the state court's adjudication of his claim was "contrary to" or an "unreasonable application of" the Court's clearly established precedents. Finding that the state court's adjudication of his claim was not, the Court reversed the Court of Appeals because "Even if we agreed with the Court of Appeals that the Double Jeopardy Clause should be read to prevent continued prosecution of a defendant under these circumstances, it was at least reasonable for the state court to conclude otherwise."

Ramdass v. Angelone

Must a jury must be instructed in the death penalty phase of sentencing that if the defendant is not given the death sentence, that he will be ineligible for parole if sentenced to life in prison?

No. In a 5-4 opinion delivered by Justice Anthony M. Kennedy, the Court held that Ramdass was not entitled to federal habeas corpus relief because he was not entitled to instruction on parole ineligibility at sentencing since conviction had not been entered yet on the earlier jury verdict making him parole ineligible. In a plurality opinion, Justice Kennedy wrote for the Court that the Virginia Supreme Court's finding that the state's three-strikes law did not cover the defendant until shortly after he was sentenced must be honored because it "was neither contrary to, nor an unreasonable application" of a decision in which the justices said that defendants have the right to tell jurors about their parole status in such cases.

Rasul v. Bush

Do United States courts have jurisdiction to consider legal appeals filed on behalf of foreign citizens held by the United States military in Guantanamo Bay Naval Base, Cuba?

Reed v. Farley, Superintendent, Indiana State Prison

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Reed v. Ross

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Rhines v. Weber

May a federal court stay a habeas petition that included exhausted and unexhausted claims, when the stay was necessary to allow a petitioner to exhaust claims in state court without having the one-year statute of limitations in the Antiterrorism and Effective Death Penalty Act (AEDPA) bar the right to a federal petition?

Yes. In a 9-0 opinion delivered by Justice Sandra Day O'Connor, the Court held that a district court could stay a mixed petition to allow a petitioner to present unexhausted claims in state court and then return to federal court. The Court recognized that its decision in Rose, combined with the one-year statute of limitations required by the AEDPA (enacted 14 years after Rose) could have permanently deprived petitioners like Rhines of the opportunity to seek federal review for unexhausted claims. As a result, federal district courts could grant a stay on a mixed petition if (1) there was good cause for the petitioner's failure to exhaust his claims in state court, (2) the unexhausted claims had merit, and (3) the petitioner was not engaged in intentionally dilatory litigation tactics.

Rice v. Collins

Does the AEDPA allow a federal court to reject the presumption of correctness for a state-court finding of fact as an "unreasonable determination of the facts," even when a rational fact finder could have determined the facts as the state court did?

No. In a unanimous decision authored by Justice Anthony Kennedy, the Court rejected the Ninth Circuit's reasoning. The Court ruled that the state court did not act unreasonably when it determined that the prosecutor's race-neutral explanations were credible. Although there might have been some evidence that could be interpreted as undermining the prosecutor's credibility, the trial court was in a better position to determine those facts. The Court faulted the Ninth Circuit for substituting "its own debatable interpretation of the record" for the trial courts findings, and for "misapplying settled rules that limit [the Circuit Court's] role and authority."

Rodriquez v. United States

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Rose v. Lundy

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Rose v. Mitchell

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Rumsfeld v. Padilla

Does Congress's "Authorization for use of Military Force" authorize the President to detain a United States citizen based on a determination that he is an enemy combatant, or is that power precluded by the Non-Detention Act?

The Court did not reach a decision on the merits in this case. Instead, in 5-to-4 opinion written by Chief Justice William H. Rehnquist, the Court found that the case had been improperly filed. Under federal law, a petition for a writ of habeas corpus can only be filed against the person directly responsible for a prisoner's confinement or, put another way, the person with the power to bring the prisoner to court. In most cases this person is the warden of the petitioner's prison; in this case, it was the commander of the military brig in which Padilla was held. Because Padilla's attorney had listed Secretary of Defense Donald Rumsfeld as the defendent, instead of the brig commander, and because the suit was filed in New York instead of in South Carolina, where the commander lived and worked, the Court found that the case would have to be re-filed in a federal district court in South Carolina.

Justices Stevens, Souter, Ginsberg and Breyer dissented, finding that an exception should be made to the jurisdictional rule because the government had moved Padilla to South Carolina without giving his attorney notice to file the habeas writ.

Saffle v. Parks

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Sanders v. United States

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Sawyer v. Smith

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Sawyer v. Whitley, Warden

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Schlanger v. Seamans

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Schlup v. Delo, Superintendent, Potosi Correctional Center

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Slack v. McDaniel

If a person's petition for a federal writ of habeas corpus is dismissed without prejudice for failure to exhaust state remedies and is re-filed after those remedies are exhausted, are any claims not raised in the first petition "second or successive" and abusive of the right?

No. In an 7-2 opinion delivered by Justice Anthony M. Kennedy, the Court held that a federal habeas corpus petition filed by a state prisoner, after an initial petition was dismissed without adjudication on the merits, does not constitute a "second or successive" petition, subject to dismissal for abuse of writ. That "a vexatious litigant could inject undue delay into the collateral review process," wrote Justice Kennedy, can be countered, "the State remains free to impose proper procedural bars to restrict repeated returns to state court for postconviction proceedings."

Smith v. Murray

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Stewart v. LaGrand

Did Walter LaGrand waive his claim that execution by lethal gas constitutes cruel and unusual punishment under the Eighth Amendment by electing to be executed by lethal gas, when Arizona's default form of execution is lethal injection?

Yes. In a per curiam opinion, the Court held that "[b]y declaring his method of execution, picking lethal gas over the state's default form of execution--lethal injection--Walter LaGrand has waived any objection he might have to it." Additionally, the Court vacated the Court of Appeals injunctive order. Justice John Paul Stevens dissented. Arguing for full briefing and argument, Justice Stevens stated that "the answer to the question whether a capital defendant may consent to be executed by an unacceptably torturous method of execution is by no means clear."

Stewart v. Martinez-Villareal

May a state prison death row inmate who already has lost on one or more federal habeas corpus petitions file a subsequent petition to claim that he cannot be executed because he is incompetent?

Yes. In a 7-2 decision, announced by Chief Justice William H. Rehnquist, the Court ruled Martinez-Villareal cannot be barred from raising his incompetency claim in a successive petition because his claim was really amended. The ban imposed by the AEDPA only covers truly successive petitions. "To hold otherwise," declared Rehnquist, "would mean that a dismissal of a first habeas petition for technical procedural reasons would bar the prisoner from ever obtaining federal habeas review."

Stone v. Powell

Were federal courts obligated to consider claims of illegal searches and seizures after such claims had been decided by state courts?

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.

Strait v. Laird

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Strickler v. Greene

Did Virginia violate Brady v. Maryland, which provides for the disclosure of all possible exculpatory evidence, when a prosecutor failed to disclose all the exculpatory materials in the police's files? Was there an acceptable reason for Tommy Strickler's failure to raise a Brady claim in state court after such an event? Would the outcome of Strickler's trial been different in presence of the exculpatory evidence?

No, yes, and no. In an opinion delivered by Justice John Paul Stevens, the Court held that although Strickler demonstrated cause for his failure to raise a Brady claim, Virginia did not violate Brady by failing to disclose exculpatory evidence to him. Further, the Court held that Strickler received a fair trial in the absence of the exculpatory evidence and did not show a "reasonable probability that his conviction or sentence would have been different had these materials been disclosed," wrote Justice Stevens for the Court.

Stringer v. Black, Commissioner, Mississippi Department Of Corrections

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Sumner v. Mata

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Swain v. Pressley

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Teague v. Lane

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Tennard v. Dretke

Does the Supreme Court's prohibition of executing mentally retarded people in Atkins v. Virginia apply if the crime cannot be attributed to mental retardation?

In a fairly narrow ruling 6-to-3 decision written by Justice Sandra Day O'Connor, the Court held that Tennard's mental retardation could reasonably be understood as relevant to his crime. Especially given the fact that the prosecutor emphasized Tennard's retardation when discussing the likelihood that he would be dangerous in the future, the Court found that the jury instructions did not sufficiently permit the jury to weigh Tennard's mental retardation in his favor.

Thompson v. Keohane, Warden

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Townsend v. Sain

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Trest v. Cain, Warden

Is a Court of Appeals required to decide issues of procedural default on its own initiative, without prompting from one of the parties ("sua sponte")?

No. A Court of Appeals is not required to raise an issue of procedural default on its own initiative. In a unanimous opinion, Justice Stephen Breyer observed: "We are not aware of any precedent stating that a habeas court must raise such a matter where the State itself does not do so." The Court held that it was the State's duty to raise issues of procedural default, but did not rule on the question of whether the Court of Appeals retained the option of ruling on the issue sua sponte.

Tyler v. Cain

Was the ruled established under Cage v. Louisiana, that a jury instruction is unconstitutional if there is a reasonable likelihood that the jury understood the instruction to allow conviction without proof beyond a reasonable doubt, "made retroactive to cases on collateral review by the Supreme Court," such that an inmate is entitled to submit successive a habeas petition based on that new rule?

No. In a 5-4 opinion by Justice Clarence Thomas, the Court held that the Cage rule was not "made retroactive to cases on collateral review by the Supreme Court." Justice Thomas wrote for the Court that "[b]ecause 'made' means 'held'...it is clear that the Cage rule has not been 'made retroactive to cases on collateral review by the Supreme Court.' Cage itself does not hold that it is retroactive. The only holding in Cage is that the particular jury instruction violated the Due Process Clause." Justice Sandra Day O'Connor filed a concurring opinion. Justice Stephen G. Breyer filed a dissenting opinion, in which Justices John Paul Stevens, David H. Souter and Ruth Bader Ginsburg joined.

United States v. Addonizio

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United States v. Frady

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United States v. Mauro

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Wainwright v. Sykes

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Wilkinson v. Dotson

(1) May a prisoner bring a claim under 42 U.S.C. 1983 claiming that his parole proceedings violate due process, even though success on the merits of the claim would result only in a new parole hearing and would not necessarily guarantee earlier release from prison? (2) Does a federal court judgment ordering a new parole hearing "necessarily imply the invalidity of" the decision at the previous parole hearing and therefore challenge the sentence itself?

Yes and No. In an 8-1 decision, the Court affirmed the appellate court and ruled that prisoners could use Section 1983 to challenge a state's parole procedures. The majority opinion by Justice Stephen Breyer held that though prisoners cannot use Section 1983 to directly challenge their sentences, they can bring suit under the Section when a successful suit "would not necessarily spell immediate or speedier release for the prisoner." Though a successful constitutional challenge to Ohio's parole procedures might make it more likely that the prisoners would be released from prison sooner, the Court called the connection "too tenuous" for the prisoners' suit to be considered a challenge of the sentences themselves. The Court ruled that since the prisoners sought only new parole hearings, not reduced sentences, a favorable ruling would not necessarily imply the invalidity of their sentences. Justice Anthony Kennedy wrote a lone dissent arguing that challenges to parole proceedings can only be brought by a petition for habeas corpus.

Williams v. Taylor

Does federal law, as amended by the Antiterrorism and Effective Death Penalty Act of 1996, bar an evidentiary hearing, if the petitioner has failed to develop the factual basis of his claims in State court proceedings despite diligent efforts?

No. In a unanimous opinion delivered by Justice Anthony M. Kennedy, the Court held that under federal law, as amended by the AEDPA, "a 'failure to develop' a claim's factual basis in state court proceedings is not established unless there is lack of diligence, or some greater fault, attributable to the prisoner or his counsel." Justice Kennedy wrote for the Court that "comity is not served by saying a prisoner 'has failed to develop the factual basis of a claim' where he was unable to develop his claim in state court despite diligent effort. In that circumstance, an evidentiary hearing is not barred."

Williams v. Taylor

Was Terry Williams' constitutional right to the effective assistance of counsel violated? Was the judgment of the Virginia Supreme Court refusing to set aside Williams' death sentence "contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States?"

Yes and yes. In a judgment announced by Justice John Paul Stevens, the Court, with different majorities of Justices for each holding, held that Williams had been deprived of the constitutional right to the effective assistance of counsel and that the Virginia Supreme Court's refusal to set aside the Williams death sentence was a decision that was contrary to or involved an unreasonable application of clearly established federal law, as determined by the Court. This conclusion followed from "'a reasonable probability that the result of the sentencing proceeding would have been different' if competent counsel had presented and explained the significance of all the available evidence.'"

Wilwording v. Swenson

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Wingo v. Wedding

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Withrow v. Williams

Does the Supreme Court's ruling in Stone v. Powell that federal habeas corpus review does not cover Fourth Amendment unreasonable search and seizure claims when defendants have already been given a fair chance to argue those claims in state court also apply to Fifth Amendment claims stemming from the withholding of Miranda warnings?

No. In an opinion written by Justice David H. Souter, the Supreme Court held that the decision in Stone had been one of prudence rather than one of jurisdiction. In Stone, the Court had decided against using the "exclusionary rule" in federal habeas cases dealing with unreasonable searches and seizures (the exclusionary rule prevents evidence discovered as the result of an unconstitutional search from being introduced in Court). The Court's decision had been based on an expectation that, even in the unlikely case that a state court had erred in its consideration of the constitutionality of a given search, that procedural error was not likely to produce a wrongful conviction. In Fifth Amendment involuntary testimony cases, though, it was possible that a suspect would given false statements about his own guilt because of confusion or fear. The question was not merely a procedural one, therefore, and the prudential concerns of Stone did not apply.

Woodford v. Garceau

Is a federal habeas petition, which was filed after the effective date of the Antiterrorism and Effective Death Penalty Act of 1996 even though a stay and counsel were sought prior to that date, "pending" for the purposes of Lindh v. Murphy, 521 U.S. 320?

No. In a 6-3 opinion delivered by Justice Clarence Thomas, the Court held, for purposes of Lindh, that a case does not become "pending" until an actual application for habeas corpus relief is filed in federal court. The Court reasoned that, because Garceau's federal habeas application was not filed until after AEDPA's effective date, it was subject to AEDPA's amendments. "If, on [the effective date of the AEDPA], the state prisoner had before a federal court an application for habeas relief seeking an adjudication on the merits of the petitioner's claims, then [the AEDPA] does not apply. Otherwise, an application filed after AEDPA's effective date should be reviewed under AEDPA, even if other filings by that same applicant...were presented to a federal court prior to AEDPA's effective date." Justice David H. Souter, joined by Justices Ruth Bader Ginsburg and Stephen G. Breyer, dissented.

Wright, Warden v. West

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Ylst v. Nunnemaker

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Younger v. Gilmore

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Zant v. Moore

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