The Oyez Project: Judicial Power Issues - Habeas Corpus Decisions

Baldwin v. Reese

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?

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.

Bell v. Cone

A Tennessee law made it an aggravating circumstance during sentencing if a murder had been "especially heinous, atrocious, or cruel." Did the state supreme court interpret that sufficiently narrowly, so that it did not run afoul of the Eighth Amendment?

Yes. In a per curiam opinion, the Court held that the Tennessee Supreme Court had in several previous cases narrowly interpreted the "especially heinous" aggravator. The state supreme court had thus made what may have been facially unconstitutional constitutional. Moreover, the court did not need to explicitly narrow the statute once more in its Cone opinion. The Court chastised the Sixth Circuit for presuming "so lightly that a state court failed to apply its own law" and rearticulated the principle that federal law demanded a "highly deferential standard for evaluating state-court rulings."

Granberry v. Greer

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Irvin v. Dowd

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