A writ of coram nobis is a legal order allowing a court to correct its original judgment upon discovery of a fundamental error that did not appear in the records of the original judgment's proceedings and that would have prevented the judgment from being pronounced. The term coram nobis is Latin for "before us" and the meaning of its full form, quae coram nobis resident, is "which [things] remain in our presence". The writ of coram nobis originated in the courts of common law in the English legal system during the sixteenth century.
Hill v. McDonough, 547 U.S. 573 (2006), was a United States Supreme Court case challenging the use of lethal injection as a form of execution in the state of Florida. The Court ruled unanimously that a challenge to the method of execution as violating the Eighth Amendment to the United States Constitution properly raised a claim under 42 U.S.C. § 1983, which provides a cause of action for civil rights violations, rather than under the habeas corpus provisions. Accordingly, that the prisoner had previously sought habeas relief could not bar the present challenge.
Day v. McDonough, 547 U.S. 198 (2006), is a US Supreme Court case involving the one-year statute of limitations for filing habeas corpus petitions that was established by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). In a 5–4 decision, the Court ruled that if the government unintentionally failed to object to the filing of a petition after the AEDPA limitations period has expired, it is not an abuse of discretion for a district court to dismiss sua sponte the petition on that basis.
In United States law, habeas corpus is a recourse challenging the reasons or conditions of a person's confinement under color of law. A petition for habeas corpus is filed with a court that has jurisdiction over the custodian, and if granted, a writ is issued directing the custodian to bring the confined person before the court for examination into those reasons or conditions. The Suspension Clause of the United States Constitution specifically included the English common law procedure in Article One, Section 9, clause 2, which demands that "The privilege of the writ of habeas corpus shall not be suspended, unless when in cases of rebellion or invasion the public safety may require it."
Panetti v. Quarterman, 551 U.S. 930 (2007), is a decision by the Supreme Court of the United States, ruling that criminal defendants sentenced to death may not be executed if they do not understand the reason for their imminent execution, and that once the state has set an execution date death-row inmates may litigate their competency to be executed in habeas corpus proceedings. This decision reaffirmed the Court's prior holdings in Ford v. Wainwright, and Stewart v. Martinez-Villareal.
In United States law, habeas corpus is a recourse challenging the reasons or conditions of a person's detention under color of law. The Guantanamo Bay detention camp is a United States military prison located within Guantanamo Bay Naval Base. A persistent standard of indefinite detention without trial and incidents of torture led the operations of the Guantanamo Bay detention camp to be challenged internationally as an affront to international human rights, and challenged domestically as a violation of the Due Process Clause of the Fifth and Fourteenth amendments of the United States Constitution, including the right of petition for habeas corpus. On 19 February 2002, Guantanamo detainees petitioned in federal court for a writ of habeas corpus to review the legality of their detention.
The Habeas Corpus Act of 1867 is an act of Congress that significantly expanded the jurisdiction of federal courts to issue writs of habeas corpus. Passed February 5, 1867, the Act amended the Judiciary Act of 1789 to grant the courts the power to issue writs of habeas corpus "in all cases where any person may be restrained of their liberty in violation of the constitution, or any treaty or law of the United States." Prior to the Act's passage, prisoners in the custody of one of the states who wished to challenge the legality of their detention could petition for a writ of habeas corpus only in state courts; the federal court system was barred from issuing writs of habeas corpus in their cases. The Act also permitted the court "to go beyond the return" and question the truth of the jailer's stated justification for detaining the petitioning prisoner, whereas prior to the Act courts were technically bound to accept the jailer's word that the prisoner was actually being held for the reason stated. The Act largely restored habeas corpus following its 1863 suspension by Congress, ensuring that anyone arrested after its passage could challenge their detention in the federal courts, but denied habeas relief to anyone who was already in military custody for any military offense or for having aided the Confederacy.
Lackawanna County District Attorney v. Coss, 532 U.S. 394 (2001), was a United States Supreme Court case. The case concerned a federal prisoner who sought to challenge his current sentence by arguing it was enhanced based on an unconstitutional prior conviction. A divided Court held that such challenges could not be brought. The decision was based on a reading of the statute in question, not a Sixth Amendment constitutional analysis.
The Supreme Court of the United States handed down eight per curiam opinions during its 2014 term, which began October 6, 2014 and concluded October 4, 2015.
McQuiggin v. Perkins, 569 U.S. 383 (2013), was a United States Supreme Court case in which the Court held that actual innocence, if proven, is sufficient to circumvent the one-year statute of limitations for petitioners to appeal their conviction enacted within the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).
Townsend v. Sain, 372 U.S. 293 (1963), was a United States Supreme Court case wherein the Court expanded the circumstances in which federal courts should hold evidentiary hearings when presented with petitions for habeas corpus by state prisoners following denial of postconviction relief in state court. The Court held that federal district courts must hold evidentiary hearings if the state court did not resolve all material factual disputes in a full and fair hearing supported by the record.
Tyler v. Cain, 533 U.S. 656 (2001) is a United States Supreme Court case in which the Court held that the rule established under Cage v. Louisiana (1990), where the Court held certain jury instructions unconstitutional because the words used did not suggest the degree of proof required by the "beyond a reasonable doubt" standard, was not "made retroactive to cases on collateral review by the Supreme Court." Tyler is the primary case regarding the retroactivity of new rules to successive habeas petitions.
Kimmelman v. Morrison, 477 U.S. 365 (1986), was a decision of the U.S. Supreme Court that clarified the relationship of the right to effective assistance of counsel under the Sixth Amendment to other constitutional rights in criminal procedure. In this case, evidence against the defendant was probably seized illegally, violating the Fourth Amendment, but he lost the chance to argue that point due to his lawyer's ineffectiveness. The prosecution argued that the defendant's attempt to make a Sixth Amendment argument via a habeas corpus petition was really a way to sneak his Fourth Amendment argument in through the back door. The Court unanimously disagreed, and held that the Fourth Amendment issue and the Sixth Amendment issue represented different constitutional values, and had different requirements for prevailing in court, and therefore were to be treated separately by rules of procedure. Therefore, the habeas corpus petition could go forward. In its opinion, the Court also gave guidance on how to apply its decisions in Stone v. Powell and Strickland v. Washington.
Stone v. Powell, 428 U.S. 465 (1976), was decision of the Supreme Court of the United States that limited which claims of Fourth Amendment violations could be made by state prisoners in habeas corpus petitions in federal courts. Specifically, a claim that the exclusionary rule had been broken would be barred if state courts had already given it a full and fair hearing. The decision combined two cases that were argued before the Supreme Court on the same day with similar issues, one filed by Lloyd Powell and the other, titled Wolff v. Rice, filed by David Rice.
Martinez v. Ryan, 566 U.S. 1 (2012), was a United States Supreme Court case which considered whether criminal defendants ever have a right to the effective assistance of counsel in collateral state post-conviction proceedings. The Court held that a procedural default will not bar a federal habeas court from hearing ineffective-assistance-of-trial-counsel if there was no counsel or ineffective counsel in an initial-review collateral proceeding.
Nelson v. Campbell, 541 U.S. 637 (2004), was a case decided by the United States Supreme Court considering whether a prisoner's appeal of proposed execution procedures was equivalent to a habeas corpus petition. The court held unanimously that an appeal of proposed execution procedures is different from a habeas corpus petition because it is not an appeal of a conviction or sentence.
Wainwright v. Sykes, 433 U.S. 72 (1977), was a United States Supreme Court case decided on June 23, 1977. In a 7–2 decision by Associate Justice William Rehnquist, the Court held that, if a state prisoner fails to raise a federal constitutional claim at trial or on appeal in a manner in keeping with the state's requirements, and cause and prejudice for this failure cannot be shown, that claim cannot be subsequently raised in federal habeas corpus proceedings. The majority adopted the "cause" and "prejudice" requirement that had been laid out in the 1976 Supreme Court decision, Francis v. Henderson, rejecting the broader standard the Court had outlined in the 1963 case Fay v. Noia. Sykes has since been recognized as one of multiple Supreme Court cases that limited the scope of its prior decision in Fay v. Noia, which the Court eventually overruled completely in the 1991 case Coleman v. Thompson. However, Sykes did not completely overrule Fay, though some scholars have argued that Sykes narrowed the scope of Fay so much as to effectively overrule it.
Fay v. Noia, 372 U.S. 391 (1963), was a 1963 United States Supreme Court case concerning habeas corpus. In a majority opinion authored by Justice William J. Brennan, Jr., the Court held that state prisoners were entitled to access to habeas relief in federal court, even if they did not pursue a remedy in state court that was not available to them at the time. Furthermore, the majority in Fay set out the "deliberate bypass" standard, whereby federal habeas courts could not deny petitions brought by state prisoners unless that prisoner had "deliberately bypassed the orderly procedure of state courts" for the adjudication of constitutional claims.
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.
Williams v. Taylor, 529 U.S. 362 (2000), was a United States Supreme Court case decided on April 18, 2000. It concerned a federal habeas corpus petition brought by convicted murderer Terry Williams, who alleged that he had received ineffective assistance of counsel in violation of the Supreme Court's prior decision in Strickland v. Washington. The Supreme Court's decision in this case was split across two majority opinions, one authored by John Paul Stevens and joined by five other justices, and the other authored by Sandra Day O'Connor and joined by four other justices.
