Cases by Issue - Adequate Non-Federal Grounds for Decision

Lee v. Kemna

Mon, 05 Jan 2009 17:46:21 +0000

Case Basics

Docket No.

00-6933

Petitioner

Lee

Petitioner Type

Petitioner

Respondent

Kemna

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

534 U.S. 362 (2002)

Argued

Monday, October 29, 2001

Decided

Tuesday, January 22, 2002

Advocates

Bonnie I. Robin-Vergeer (Argued the cause for the petitioner)

Paul C. Wilson (Jefferson City, Missouri, argued the cause for the respondent)

Facts of the Case

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.

Question

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?

Conclusion

Decision: 6 votes for Lee, 3 vote(s) against
Legal provision:

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

Mon, 05 Jan 2009 17:27:13 +0000

Case Basics

Docket No.

85-217

Appellee

Davis

Petitioner Type

Appellee

Appellant

Longshoremen

Respondent Type

Appellant

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

476 U.S. 380 (1986)

Argued

Tuesday, February 25, 1986

Decided

Tuesday, May 27, 1986

Advocates

Bayless E. Biles (on behalf of Appellee)

Charles R. Goldburg (on behalf of Appellant)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Davis, 0 vote(s) against
Legal provision: National Labor Relations, as amended

None

Ake v. Oklahoma

Mon, 05 Jan 2009 17:20:35 +0000

Case Basics

Docket No.

83-5424

Petitioner

Ake

Petitioner Type

Petitioner

Respondent

Oklahoma

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

470 U.S. 68 (1985)

Argued

Wednesday, November 7, 1984

Decided

Wednesday, February 20, 1985

Advocates

Michael C. Turpen (on behalf of the respondent)

Arthur B. Spitzerm (on behalf of the petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Ake, 1 vote(s) against
Legal provision: Due Process

None

Colorado v. Nunez

Mon, 05 Jan 2009 17:29:24 +0000

Case Basics

Docket No.

82-1845

Petitioner

Colorado

Petitioner Type

Petitioner

Respondent

Nunez

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

465 U.S. 324 (1984)

Argued

Tuesday, January 17, 1984

Decided

Tuesday, February 21, 1984

Advocates

Steven Leon Bernard (on behalf of the Petitioner)

Kenneth H. Stern (on behalf of the Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Nunez, 0 vote(s) against
Legal provision: Writ Improvidently Granted

None

Florida v. Casal

Mon, 05 Jan 2009 17:32:40 +0000

Case Basics

Docket No.

81-2318

Petitioner

Florida

Petitioner Type

Petitioner

Respondent

Casal

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

462 U.S. 637 (1983)

Argued

Wednesday, February 23, 1983

Decided

Friday, June 17, 1983

Advocates

Arthur F. McCormick (on behalf of the Respondent)

Carolyn M. Snurkowski (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Casal, 0 vote(s) against
Legal provision: Writ Improvidently Granted

None

Oregon v. Kennedy

Mon, 05 Jan 2009 17:30:27 +0000

Case Basics

Docket No.

80-1991

Petitioner

Oregon

Respondent

Kennedy

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

456 U.S. 667 (1982)

Argued

Monday, March 29, 1982

Decided

Monday, May 24, 1982

Advocates

David B. Frohnmayer (on behalf of the Petitioner)

Samuel A. Alito, Jr. (on behalf of the United States as amicus curiae)

Donald C. Walker (on behalf of the Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Oregon, 0 vote(s) against
Legal provision: Double Jeopardy

None

Paschall v. Christie-Stewart, Inc.

Mon, 05 Jan 2009 16:34:40 +0000

Case Basics

Docket No.

72-922

Appellee

Christie-Stewart, Inc.

Petitioner Type

Appellee

Appellant

Paschall

Respondent Type

Appellant

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

414 U.S. 100 (1973)

Argued

Tuesday, October 16, 1973

Decided

Monday, November 19, 1973

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Paschall, 2 vote(s) against
Legal provision:

None

Mental Hygiene Dept. v. Kirchner

Mon, 05 Jan 2009 17:34:35 +0000

Case Basics

Docket No.

111

Petitioner

Mental Hygiene Dept.

Petitioner Type

Petitioner

Respondent

Kirchner

Respondent Type

Respondent

Heard By

Warren Court (1962-1965)

Decided By

Warren Court (1962-1965)

Opinion

380 U.S. 194 (1965)

Argued

Tuesday, January 19, 1965

Decided

Monday, March 8, 1965

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Mental Hygiene Dept., 1 vote(s) against
Legal provision:

None

Jankovich v. Toll Road Comm'n

Mon, 05 Jan 2009 17:34:21 +0000

Case Basics

Docket No.

Petitioner

Jankovich

Petitioner Type

Petitioner

Respondent

Toll Road Comm'n

Respondent Type

Respondent

Heard By

Warren Court (1962-1965)

Decided By

Warren Court (1962-1965)

Opinion

379 U.S. 487 (1965)

Argued

Thursday, December 10, 1964

Decided

Monday, January 18, 1965

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Toll Road Comm'n, 2 vote(s) against
Legal provision: 49 U.S.C. 1101

None

Henry v. Mississippi

Mon, 05 Jan 2009 17:34:12 +0000

Case Basics

Docket No.

Petitioner

Henry

Petitioner Type

Petitioner

Respondent

Mississippi

Respondent Type

Respondent

Heard By

Warren Court (1962-1965)

Decided By

Warren Court (1962-1965)

Opinion

379 U.S. 443 (1965)

Argued

Tuesday, October 13, 1964

Decided

Monday, January 18, 1965

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Henry, 3 vote(s) against
Legal provision:

None

Wright v. Georgia

Mon, 05 Jan 2009 17:38:21 +0000

Case Basics

Docket No.

Petitioner

Wright

Petitioner Type

Petitioner

Respondent

Georgia

Respondent Type

Respondent

Heard By

Warren Court (1962-1965)

Decided By

Warren Court (1962-1965)

Opinion

373 U.S. 284 (1963)

Argued

Wednesday, November 7, 1962

Decided

Monday, May 20, 1963

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Wright, 0 vote(s) against
Legal provision: Equal Protection

None

Wolfe v. North Carolina

Mon, 05 Jan 2009 16:30:26 +0000

Case Basics

Docket No.

Petitioner

North Carolina

Respondent

Wolfe

Heard By

Warren Court (1958-1962)

Decided By

Warren Court (1958-1962)

Opinion

364 U.S. 177 (1960)

Argued

October 19-20, 1959

Decided

Monday, June 27, 1960

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for North Carolina, 4 vote(s) against
Legal provision:

None

Ivanhoe Irrig. Dist. v. Mccracken

Mon, 05 Jan 2009 16:29:45 +0000

Case Basics

Docket No.

122

Petitioner

Ivanhoe Irrig. Dist.

Respondent

Mccracken

Consolidation

No. 123

No. 124

No. 125

Heard By

Warren Court (1957-1958)

Decided By

Warren Court (1957-1958)

Opinion

357 U.S. 275 (1958)

Argued

Tuesday, April 29, 1958

Decided

Monday, June 23, 1958

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Ivanhoe Irrig. Dist., 0 vote(s) against
Legal provision: Takings Clause

None

NAACP v. Alabama

Mon, 20 Jun 2011 04:05:58 +0000

Location

Alabama State Capitol

600 Dexter Avenue Montgomery AL 36104

Montgomery, AL 36104

United States

32° 22' 39.5544" N, 86° 18' 6.786" W

See map: Google Maps

Case Basics

Docket No.

Petitioner

National Association for the Advancement of Colored People

Petitioner Type

Petitioner

Respondent

Alabama

Respondent Type

Respondent

Heard By

Warren Court (1957-1958)

Decided By

Warren Court (1957-1958)

Opinion

357 U.S. 449 (1958)

Argued

January 15-16, 1958

Decided

Monday, June 30, 1958

Advocates

Robert L. Carter (Argued the cause for the petitioner)

Edmon L. Rinehart (Argued the cause for the respondent)

Facts of the Case

As part of its strategy to enjoin the NAACP from operating, Alabama required it to reveal to the State's Attorney General the names and addresses of all the NAACP's members and agents in the state.

Question

Did Alabama's requirement violate the Due Process Clause of the Fourteenth Amendment?

Conclusion

Decision: 9 votes for NAACP, 0 vote(s) against
Legal provision: Association

Yes. The unanimous Court held that a compelled disclosure of the NAACP's membership lists would have the effect of suppressing legal association among the group's members. Nothing short of an "overriding valid interest of the State," something not present in this case, was needed to justify Alabama's actions.

Wilson v. Loew's Inc.

Mon, 05 Jan 2009 16:29:40 +0000

Case Basics

Docket No.

Petitioner

Wilson

Petitioner Type

Petitioner

Respondent

Loew's Inc.

Respondent Type

Respondent

Heard By

Warren Court (1957-1958)

Decided By

Warren Court (1957-1958)

Opinion

355 U.S. 597 (1958)

Argued

Wednesday, January 8, 1958

Decided

Monday, March 3, 1958

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Loew's Inc., 1 vote(s) against
Legal provision: Writ Improvidently Granted

None

Staub v. City Of Baxley

Mon, 05 Jan 2009 16:29:41 +0000

Case Basics

Docket No.

Petitioner

City Of Baxley

Respondent

Staub

Heard By

Warren Court (1957-1958)

Decided By

Warren Court (1957-1958)

Opinion

355 U.S. 313 (1958)

Argued

November 18-19, 1957

Decided

Monday, January 13, 1958

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Staub, 2 vote(s) against
Legal provision: Amendment 1: Speech, Press, and Assembly

None

Black v. Cutter Laboratories

Mon, 05 Jan 2009 16:25:36 +0000

Case Basics

Docket No.

Petitioner

Black

Petitioner Type

Petitioner

Respondent

Cutter Laboratories

Respondent Type

Respondent

Heard By

Warren Court (1955-1956)

Decided By

Warren Court (1955-1956)

Opinion

351 U.S. 292 (1956)

Argued

Thursday, April 26, 1956

Decided

Monday, June 4, 1956

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Cutter Laboratories, 3 vote(s) against
Legal provision:

None

Durley v. Mayo

Mon, 05 Jan 2009 16:25:46 +0000

Case Basics

Docket No.

489

Petitioner

Durley

Petitioner Type

Petitioner

Respondent

Mayo

Respondent Type

Respondent

Heard By

Warren Court (1955-1956)

Decided By

Warren Court (1955-1956)

Opinion

351 U.S. 277 (1956)

Argued

Monday, April 2, 1956

Decided

Monday, June 4, 1956

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Mayo, 4 vote(s) against
Legal provision:

None

Uphaus v. Wyman

Mon, 05 Jan 2009 17:37:43 +0000

Case Basics

Docket No.

336

Appellee

Wyman

Petitioner Type

Appellee

Appellant

Uphaus

Respondent Type

Appellant

Decided By

Warren Court (1958-1962)

Opinion

364 U.S. 388 (1960)

Decided

Monday, November 14, 1960

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Wyman, 3 vote(s) against
Legal provision:

None

Parrot v. Tallahassee

Mon, 05 Jan 2009 17:34:10 +0000

Case Basics

Docket No.

958

Petitioner

Parrot

Petitioner Type

Petitioner

Respondent

Tallahassee

Respondent Type

Respondent

Decided By

Warren Court (1962-1965)

Opinion

381 U.S. 129 (1965)

Decided

Monday, May 3, 1965

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Parrot, 0 vote(s) against
Legal provision:

None

Stewart v. Smith

Mon, 05 Jan 2009 17:46:40 +0000

Case Basics

Docket No.

01-339

Appellee

Smith

Petitioner Type

Appellee

Appellant

Stewart

Respondent Type

Appellant

Decided By

Rehnquist Court (1994-2005)

Opinion

534 U.S. 157 (2001)

Decided

Wednesday, December 12, 2001

Facts of the Case

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.

Question

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

Conclusion

Decision: 9 votes for Stewart, 0 vote(s) against
Legal provision:

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?"