Coleman v. Thompson

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Coleman v. Thompson
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued February 25, 1991
Decided June 24, 1991
Full case name Roger Keith Coleman, Petitioner v. Charles E. Thompson, Warden
Citations501 U.S. 722 ( more )
111 S.Ct. 2546, 115 L.Ed.2d 640
Argument Oral argument
Case history
Prior895 F. 2d 139 (CA4 1990)
Holding
Coleman's claims presented for the first time in the state habeas proceeding are not subject to review in federal habeas.
Court membership
Chief Justice
William Rehnquist
Associate Justices
Byron White  · Thurgood Marshall
Harry Blackmun  · John P. Stevens
Sandra Day O'Connor  · Antonin Scalia
Anthony Kennedy  · David Souter
Case opinions
MajorityO'Connor, joined by Rehnquist, White, Scalia, Kennedy, Souter
ConcurrenceWhite
DissentBlackmun, joined by Marshall, Stevens
This case overturned a previous ruling or rulings
Fay v. Noia (1963)

Coleman v. Thompson, 501 U.S. 722 (1991), was a case decided by the Supreme Court of the United States on June 24, 1991. The Court held that the petitioner, convicted murderer Roger Keith Coleman, was barred from raising his claims of federal constitutional violations in a federal habeas court, because he had previously procedurally defaulted these claims in state habeas proceedings. This default had occurred because Coleman's lawyers inadvertently filed their notice of appeal three days later than required by the rules of the Supreme Court of Virginia. [1]

Contents

Supreme Court

The majority opinion in Coleman v. Thompson was written by Justice Sandra Day O'Connor and joined by five other justices: William Rehnquist, Byron White, Antonin Scalia, Anthony Kennedy, and David Souter. Coleman explicitly overturned the "deliberate bypass" standard the Court had adopted in the 1963 decision in Fay v. Noia , under which federal habeas courts could only dismiss habeas petitions by state prisoners if those prisoners had deliberately avoided raising their claims in state court. [2] [3] In place of the Fay standard, the Coleman majority adopted the "cause and prejudice" standard that the Court had advanced in multiple other decisions since Fay, notably in its 1977 decision in Wainwright v. Sykes . Under this standard, prisoners whose federal constitutional claims were previously procedurally defaulted in state courts are barred from raising them in federal courts unless they could "demonstrate cause for the default and actual prejudice as a result of the alleged violation of federal law, or demonstrate that failure to consider the claims will result in a fundamental miscarriage of justice." [4]

O'Connor's majority opinion began with the sentence "This is a case about federalism", indicating that she placed a high priority on federal courts deferring to state laws and procedures regarding how prisoners can challenge their convictions. [1] [5] The dissenting opinion, written by Justice Harry Blackmun, responded to O'Connor's assertion by arguing that federalism "has no inherent normative value: it does not, as the majority appears to assume, blindly protect the interests of States from any incursion by the federal courts. Rather, federalism secures to citizens the liberties that derive from the diffusion of sovereign power." [6] The Coleman majority opinion also asserted that petitioners in federal habeas proceedings must "bear the risk of attorney error", because the constitutional right to counsel does not extend to such proceedings; the Supreme Court has relaxed this rule somewhat in some of its more recent decisions, including Maples v. Thomas . [7]

Reactions and impact

Shortly after the Supreme Court decided Coleman v. Thompson, the New York Times published an editorial harshly criticizing the decision. The editorial argued that the Court holding that Coleman was unable to challenge his conviction in federal court solely because his attorneys had narrowly missed a filing deadline was "bizarre". It further dismissed O'Connor's invocation of federalism as a justification for this decision, writing that "[i]n the name of states' rights, the Court has produced a terrible injustice." [8] The decision was also met with criticism from civil rights activists, who saw it as part of a trend of Rehnquist Court decisions aimed at restricting access to habeas corpus for state prisoners. [9] Congressman Don Edwards was also critical of the decision, saying that "Coleman might very well be innocent, yet the Supreme Court has used this arbitrary rule that he can’t take advantage of habeas corpus just because it wasn’t technically filed correctly". [10]

On May 14, 1992, shortly before Coleman was scheduled to be executed, the New York Times published another editorial criticizing the Supreme Court's decision in Coleman. The editorial claimed that the Supreme Court was "determined to facilitate executions and excessively deferential to dubious state court rulings". [11] On May 18, Time published an issue with Coleman on the cover and the caption "Must This Man Die?" The article, written by Jill Smolowe, argued that "the courts have so far failed Coleman miserably" and criticized the Court's decision in Coleman as part of a pattern whereby the Rehnquist Court was "more concerned with finality than fairness". [10] Coleman was executed on May 20, 1992, after his final appeals were rejected by the Supreme Court in a 7–2 vote, with Justices Blackmun and David Souter dissenting. [12]

In a 2001 article in Salon , journalist Alan Burlow described Coleman as "one of the Court's most criticized death penalty decisions in recent memory". [13] In 2006, DNA evidence confirmed that Coleman was guilty of the crimes for which he was executed, despite having insisted that he was innocent up until his execution. [14] In 2007, law professor Todd Pettys criticized Coleman as part of the court's "overarching, finality-driven reform agenda." He also criticized the Coleman majority for what he felt was its excessive focus on finality, writing that "when procedural requirements are so rigorously enforced that the public is given good cause to believe that courts ascribe greater value to procedural impeccability than to substantive justice, citizens justifiably lose confidence in the integrity of the criminal justice system. At that point, it is only the rhetoric - and not the reality - of finality that has triumphed." [2]

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References

  1. 1 2 Althouse, Ann (1992–1993). "Variations on a Theory of Normative Federalism: A Supreme Court Dialogue". Duke Law Journal. 42 (5): 979–1021. doi:10.2307/1372787. JSTOR   1372787.
  2. 1 2 Pettys, Todd (May 1, 2007). "Killing Roger Coleman: Habeas, Finality, and the Innocence Gap". William & Mary Law Review. 48 (6): 2313. ISSN   0043-5589.
  3. ↑ Inafuku, Rae (January 1, 1994). "Coleman v. Thompson - Sacrificing Fundamental Rights in Deference to the States: The Supreme Court's 1991 Interpretation of the Writ of Habeas Corpus". Santa Clara Law Review. 34 (2): 625. ISSN   0146-0315.
  4. ↑ Coleman v. Thompson, 501 U.S. 722, 724 (1991)
  5. ↑ Frankel, Glenn (May 14, 2006). "Burden of proof". Washington Post. ISSN   0190-8286 . Retrieved May 24, 2024. "This is a case about federalism," wrote Justice Sandra Day O'Connor for the majority, seemingly more concerned about state court prerogatives than the fact that Coleman's life was at stake.
  6. ↑ Coleman v. Thompson, 501 U.S. 722, 759 (1991) (Blackmun, J., dissenting)
  7. ↑ Zupac, Wendy Zorana (2012–2013). "Mere Negligence or Abandonment: Evaluating Claims of Attorney Misconduct After Maples v. Thomas". Yale Law Journal. 122: 1328.
  8. ↑ "Federalism, Despoiled". The New York Times. June 27, 1991. ISSN   0362-4331 . Retrieved May 25, 2024.
  9. ↑ "CLOUDS HANG OVER VA. MOUNTAIN MURDER AS EXECUTION NEARS". Washington Post. January 3, 2024. ISSN   0190-8286 . Retrieved May 25, 2024.
  10. 1 2 Smolowe, Jill (May 18, 1992). "Roger Keith Coleman: Must This Man Die?". Time. Retrieved May 25, 2024.
  11. ↑ "Deep Doubts About a Death". The New York Times. May 14, 1992. ISSN   0362-4331 . Retrieved May 25, 2024.
  12. ↑ Jackson, Robert L.; Savage, David G. (May 21, 1992). "Final Appeals Rejected, Killer Is Executed". Los Angeles Times. Retrieved May 25, 2024.
  13. ↑ Berlow, Alan (July 5, 2001). "A Supreme Court shocker" . Retrieved May 25, 2024.
  14. ↑ "DNA tests confirm executed man's guilt". NBC News. January 12, 2006. Retrieved June 4, 2024.
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