Brown v. Allen
| Brown v. Allen | |
|---|---|
 | |
| Argued April 29, 1952 Reargued October 13, 1952 Decided February 9, 1953 | |
| Full case name | Brown v. Allen |
| Citations | 344 U.S. 443 (more) |
| Holding | |
| A failure to use a state's available remedy, in the absence of some interference or incapacity, bars federal habeas corpus. | |
| Court membership | |
| |
Brown v. Allen, 344 U.S. 443 (1953), is a landmark United States Supreme Court case about habeas corpus.[1]
Background
[edit]United States courts are authorized by statute (28 USC §2241 pursuant to §2254) to grant habeas relief to prisoners who have been convicted by a state court.[2]
Justice Felix Frankfurter concurring in Brown notes the "uniqueness" of habeas corpus is its availability to "bring into question the legality of a person's restraint and to require justification for such detention".[3] Justice Chase said habeas corpus has long been considered "the best and only sufficient defence of personal freedom".
Case history
[edit]The named petitioner Brown was convicted of rape and sentenced to death by the state of North Carolina in 1950. He challenged the indictment alleging discrimination in the selection of grand jurors. He also challenged the admission into evidence of a confession he claimed was coerced. The state supreme court affirmed the conviction.[4]
In two of the cases Speller v. Crawford (99 F. Supp 92) and Daniels v. Crawford (99 F. Supp. 208) the district court heard new evidence in addition to the trial and appellate records. In Brown v. Crawford (98 F. Supp. 866) the district court accepted the findings of the sentencing judge without considering new evidence.[5]
Supreme Court
[edit]Brown v. Allen held that federal courts had statutory authority to hear collateral attacks on state convictions for constitutional error. There were two major opinions: the formal opinion of Justice Reed and a separate opinion by Justice Frankfurter.[6]
Opinion of the Court
[edit]The Supreme Court said the decision of a state court about the legality of a prisoner's detention made "on the facts presented" does not require a new hearing "on the merits, facts or law" if the reviewing federal court is "satisfied that federal constitutional rights have been protected".[6][7] Brown alleged that the District Court's refusal in his case to "hear again the controversy notwithstanding prior determinations" of the highest state court was procedural error.[8] While state adjudication is not res judicata for mixed questions of law, federal courts may dismiss petitions if they are "satisfied, by the record, that the state process has given fair consideration...and has resulted in a satisfactory conclusion."[9][10][6]
Writing separately Justice Felix Frankfurter said that "state adjudication of questions of law cannot, under the habeas corpus statute, be accepted as binding."[11] He says "so-called mixed questions" require adjudication by a federal judge.[12][6]
State procedural rules may require that certain errors be raised by appeal. Failing to exhaust available state remedies is a clear ground to deny habeas applications.[13] Procedural default is a rigid bar to relief.[14]
In Daniels v. Allen the petitioners were convicted of murder and sentenced to death. The statement of the case on appeal served one day late was rejected as time-barred under North Carolina law. Federal courts are authorized to hear habeas petitions challenging detention by state officials under 28 USC § 2241 only when a prisoner is in custody in violation of the laws of the United States. Brown gives several examples of situations where procedural default would not bar consideration of claims on federal habeas review: "where time has expired without appeal when the prisoner is detained without opportunity to appeal because of lack of counsel, incapacity, or some interference by officials". The Court noted that petitioners had counsel and were not obstructed: "The state furnished an adequate and easily-complied-with method of appeal. This included a means to serve the statement of the case on appeal in the absence of the prosecutor from his office". Petitioners failure to appeal was a bar to habeas relief.[15][16]
Dissent
[edit]Justice Jackson said the "vague and unsettled" requirements of substantive due process allowed "floods of stale, frivolous and repetitious petitions".[9] He says habeas relief should be limited to jurisdictional questions where a state denied a prisoner in custody access to state courts or improperly obstructed him from making a record.[17]
References
[edit]- ^ "ArtIII.S1.6.9 Habeas Review". Constitution Annotated.
In later cases, the Court abandoned its emphasis upon want of jurisdiction and held that the writ was available to consider constitutional claims as well as questions of jurisdiction. The landmark case was Brown v. Allen, in which the Court laid down several principles of statutory construction of the habeas statute. First, all federal constitutional questions raised by state prisoners are cognizable in federal habeas. Second, a federal court is not bound by state court judgments on federal questions, even though the state courts may have fully and fairly considered the issues. Third, a federal habeas court may inquire into issues of fact as well as of law, although the federal court may defer to the state court if the prisoner received an adequate hearing. Fourth, new evidentiary hearings must be held when there are unusual circumstances, when there is a vital flaw in the state proceedings, or when the state court record is incomplete or otherwise inadequate.
- ^ "Federal Habeas Corpus Review of State Convictions: An Interplay of Appellate Ambiguity and District Court Discretion" (PDF). Yale Law Journal. 68.
- ^ Brown v. Allen, 344 U.S. 443, 512
- ^ Brown v. Allen, 344 U.S. 443, 466
- ^ Brown v. Allen, 344 U.S. 443, 454
- ^ a b c d Report to the Attorney General on Federal Habeas Corpus Review of State Judgments (Report). United States Department of Justice Office of Legal Policy. 1988.
- ^ Brown v. Allen, 344 U.S. 443, 464, 465
- ^ Brown v. Allen, 344 U.S. 443, 460
- ^ a b Friendly, Henry. "Is Innocence Irrelevant? Collateral Attack on Criminal Judgments". The University of Chicago Law Review. 38 (142).
- ^ Brown v. Allen, 344 U.S. 443, 458, 463
- ^ Brown v. Allen, 344 U.S. 443, 506
- ^ Brown v. Allen, 344 U.S. 443, 508
- ^ Brown v. Allen, 344 U.S. 443, 483-85, 502, 503
- ^ Garrett, Brandon L.; Phillips, Kaitlin (2022). "AEDPA Repeal". Cornell Law Review. 107: 1748–53.
- ^ Brown v. Allen at 485
- ^ Wright, J. Skelly; Sofaer, Abraham D. (1966). "Federal Habeas Corpus For State Prisoners: The Allocation of Fact-Finding Responsibility". The Yale Law Journal. 85 (5): 966.
A bypass ruling is...improper where the defendant is unrepresented, if he lacked capacity to make a deliberate decision.
- ^ Brown v. Allen, 344 U.S. 443, 545
External links
[edit]Text of Brown v. Allen, 344 U.S. 443 (1953) is available from: Justia Library of Congress