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

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

While on trial for first-degree murder, Remon Lee planned an alibi defense. His mother, stepfather, and sister were to voluntarily testify that he was in California at the time of the murder. The day the defense was to begin its case, the three could not be found. Lee's counsel moved for an overnight continuance to gain time to find the witnesses. The trial judge denied the motion. Subsequently, no alibi witnesses testified, the jury found Lee guilty, and he was sentenced to prison for life without possibility of parole. The Missouri Court of Appeals eventually disposed of the case on state procedural grounds. The appeals court held that the denial of the continuance motion was proper because Lee's counsel had failed to comply with Missouri Supreme Court Rule 24.09, which requires that such motions be in writing and accompanied by an affidavit, and with Rule 24.10, which sets out the showings a movant must make to gain a continuance grounded on witnesses' absence. Ultimately, the Federal Court of Appeals ruled that federal review of Lee's claim, that the refusal to grant his continuance motion deprived him of his federal due process right to a defense, was unavailable because the state court's rejection of that claim rested on state-law grounds, independent of the federal question and adequate to support the judgment.

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

Robert Smith was convicted of first-degree murder and sentenced to death. Smith filed a series of petitions for state postconviction relief, alleging that his trial and appellate counsel were ineffective. The Superior Court denied Smith's claims, finding them waived under Arizona Rule 32.2(a)(3) because he failed to raise them in his previous Rule 32 petitions. The court rejected Smith's argument that his failure to raise these claims was also due to ineffective assistance because his prior appellate and Rule 32 counsel, who are members of the Arizona Public Defender's office, refused to file ineffective assistance of counsel claims because his trial counsel was also a member of the Public Defender's office. The Federal District Court held that Smith's claim was barred by the lower court's procedural ruling. In reversing, the Court of Appeals held that the state procedural default was not independent of federal law and thus did not bar federal review of the merits of Smith's claim. The appellate court reasoned that Arizona Rule 32.2(a)(3) applies a different standard for waiver depending on whether the claim asserted in a Rule 32 petition was of sufficient constitutional magnitude and that determination whether a claim is of sufficient magnitude required consideration of the merits of the claim.

Wilson v. Loew's Inc.

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