Law School Case Brief
Brown v. Allen - 344 U.S. 443, 73 S. Ct. 397 (1953)
When an application for habeas corpus by a state prisoner is filed in a federal district court after the exhaustion of state remedies, including a certiorari to the Supreme Court, it rests on a record that was made in the applicant's effort to secure relief through the state from imprisonment, allegedly in violation of federal constitutional rights. The district court, a court convenient to the place of litigation, 28 U.S.C.S. § 2241(b), after determining grounds for relief are stated in the petition, may require a showing of the record and action on prior applications.
Several prisoners who, in separate trials, had been convicted of capital felonies and sentenced to death by North Carolina courts filed applications for habeas corpus in the Federal District Court, alleging that their convictions were vitiated by disregard of federal constitutional rights. It was alleged that the selection of jurors on the basis of property tax lists resulted in discrimination against black defendants, with the result that fewer black residents than white residents, having regard for their proportion of the population, appeared on the panels. In Nos. 20 and 32, it was also alleged that due process was violated by the use of coerced confessions. Finally, in No. 20, the conviction was challenged on the additional ground that the state appellate court, in violation of due process, had refused to hear defendant's appeal on the merits. In two cases (Nos. 22 and 32) the constitutional questions had been already raised and adversely decided by the state trial court; the trial court's action had been affirmed by the highest state court; and the United States Supreme Court had denied certiorari. In the third case (No. 20) the highest court of the state, although having discretion to hear the appeal, dismissed the appeal because the prisoner's attorneys had not served a statement of the case until one day after lapse of the sixty-days' period allowed by the trial court. In that case also, certiorari was denied by the United States Supreme Court.
The Federal District Court dismissed the petitions for habeas corpus, and the dismissals were affirmed by the Court of Appeals. In Nos. 22 and 32 the decision was rested on the ground that, if the United States Supreme Court has denied certiorari after a state court decision on the merits, a federal district court will not usually re-examine on habeas corpus the questions so adjudicated. In No. 20 certiorari was denied on the ground that the federal questions had been adversely decided by the state trial court, even though the defendants had lost their full right of review through failure to comply with local rules.
Did the district court properly deny the petitions for habeas corpus?
The United States Supreme Court affirmed, holding that although the lower court erred in considering its prior denial of certiorari, such error was not grounds for a new trial because the lower court properly denied writs after examining state records and determining that the prisoners were not held in custody in violation of the federal constitution. With regard to the constitutional issues, the lower court properly held that there was no violation of the Fourteenth Amendment or the Equal Protection Clause in the use of a tax list that was nondiscriminatory to race as a source of jurors. Finally, the Court held that the state's refusal to review the petition after failure to perfect the case on appeal did not violate the federal constitution. Petitioners' failure to use the available state remedy barred federal habeas corpus relief. The fact that the time for appeal passed was not enough to empower the Court to issue a writ of habeas corpus.
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