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Law School Case Brief

Stone v. Powell - 428 U.S. 465, 96 S. Ct. 3037 (1976)

Rule:

Where the State has provided an opportunity for full and fair litigation of a claim under the Fourth Amendment, a state prisoner may not be granted federal habeas corpus relief on the ground that evidence obtained in an unconstitutional search or seizure was introduced at his trial.

Facts:

Two state prisoners, Powell and Rice, both convicted of homicide, one in a California and the other in a Nebraska state court, sought federal habeas corpus relief under 28 U.S.C.S. § 2254 on the ground that at the respective state trials evidence obtained by an unconstitutional search and seizure was introduced. In each case, the issue was presented to the state court. The California prisoner's petition for habeas corpus was denied by the United States District Court for the Northern District of California, but the United States Court of Appeals for the Ninth Circuit reversed. The Nebraska prisoner's petition for the same writ was granted by the United States District Court for Nebraska and the United States Court of Appeals for the Eighth Circuit affirmed.

Issue:

Were state prisoners entitled to federal habeas corpus relief on the ground that evidence obtained in an unconstitutional search and seizure was introduced at trial?

Answer:

No

Conclusion:

On certiorari, the Supreme Court of the United States held that the constitutional protections accorded criminal defendants under the exclusionary rule of the Fourth Amendment were not absolute but had to be weighed against competing policies. The Court noted that the contribution of the exclusionary rule to the effectuation of the Fourth Amendment was minimal, while the substantial societal costs of application of the rule persisted with special force. Accordingly, the Court reversed and held that where the State had provided an opportunity for full and fair litigation of a claim under the Fourth Amendment, state prisoners should not have been granted federal habeas corpus relief on the ground that evidence obtained in an unconstitutional search and seizure was introduced at trial.

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