The Oyez Project: Judicial Power Issues - Adequate Non-Federal Grounds for Decision Decisions

Black v. Cutter Laboratories

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Colorado v. Nunez

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Durley v. Mayo

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Florida v. Casal

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Henry v. Mississippi

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Jankovich v. Toll Road Comm'n

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Lee v. Kemna

Is a defendant's imperfect compliance with Missouri court rules an adequate state ground to preclude the federal habeas corpus review of his claim that a Missouri trial judge's refusal to grant an overnight continuance violated due process?

No. In a 6-3 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that the Missouri Rules, as injected into this case by the state appellate court, did not constitute a state ground adequate to bar federal habeas review. The Court reasoned that the dispositive issue was that the accused's asserted due process right to defend ought not to depend on a formal ritual that would further no perceivable state interest. "Caught in the midst of a murder trial and unalerted to any procedural defect in his presentation, defense counsel could hardly be expected to divert his attention from the proceedings rapidly unfolding in the courtroom and train, instead, on preparation of a written motion and affidavit," wrote Justice Ginsburg. Justice Anthony M. Kennedy, joined by Justices Antonin Scalia and Clarence Thomas, dissented, arguing that the decision had committed the Court to a problematic course concerning the adequacy of state procedural grounds to bar subsequent federal review.

Longshoremen v. Davis

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Mental Hygiene Dept. v. Kirchner

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Paschall v. Christie-Stewart, Inc.

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Stewart v. Smith

Did the Court of Appeals err in interpreting Arizona law concerning its postconviction-relief rule?

In a per curiam opinion, the Court granted certiorari to review the Court of Appeals holding. The Court reasoned that in order to determine whether the District Court may review Smith's claims, it first had to know whether the Court of Appeals properly interpreted Arizona law concerning Rule 32.2(a)(3) and, therefore, certified the following question to the Arizona Supreme Court: "At the time of respondent's third Rule 32 petition in 1995, did the question whether an asserted claim was of 'sufficient constitutional magnitude' to require a knowing, voluntary and intelligent waiver for purposes of Rule 32.2(a)(3) depend upon the merits of the particular claim or merely upon the particular right alleged to have been violated?"

Wilson v. Loew's Inc.

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