Amadeo v. Zant

Supreme Court of the United States · 1988 · Federal Courts

Federal CourtsHabeas CorpusProcedural DefaultCause and PrejudiceAppellate Reviewfederal habeasprocedural defaultcause and prejudice

Facts

Amadeo was convicted of murder and sentenced to death in Georgia. After trial, a separate federal civil action uncovered a handwritten memorandum from the District Attorney's Office instructing jury commissioners to underrepresent black people and women on county master jury lists by percentages designed to avoid a prima facie discrimination showing. Amadeo's lawyers raised the jury-composition claim as soon as that evidence came to light, but the Georgia Supreme Court held the challenge came too late under state procedural rules. In federal habeas proceedings, the District Court found the memorandum had been concealed by county officials and that counsel had not deliberately bypassed the challenge.

Issue

Whether the Court of Appeals properly overturned the District Court's factual findings that county officials concealed the basis of Amadeo's jury-discrimination claim and that his lawyers did not make a tactical decision to forgo the claim. Put differently, the question was whether those findings were clearly erroneous so as to defeat cause for procedural default.

Rule

Cause for a state procedural default exists when some objective factor external to the defense impeded counsel's compliance with the state procedural rule, including when the factual basis of a claim was not reasonably available to counsel or when officials interfered with discovery of the claim. A tactical or intentional decision to forgo a claim ordinarily does not constitute cause. On appeal, a district court's factual findings on those matters may be set aside only if clearly erroneous, and when there are two permissible views of the evidence, the factfinder's choice between them cannot be clearly erroneous.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a federal habeas case from Alabama, Devon Pike argues he defaulted a jury-selection claim by not raising it before trial. At an evidentiary hearing in Birmingham, the district judge finds that a county clerk had tucked an unsigned instruction sheet about excluding young renters into an unlabeled stack of archived materials, and that defense counsel raised the claim promptly once a civil-rights lawyer fortuitously found it years later.

If the state appeals, which is the strongest basis for affirming the district court’s finding of cause?

Explanation. The governing rule is that cause for procedural default exists when some objective factor external to the defense impeded compliance with the state rule, including when the factual basis of the claim was not reasonably available or officials interfered with discovery. A concealed or effectively undiscoverable document found only fortuitously fits that rule. The majority did not hold that seriousness alone establishes cause, that later diligence alone is enough, or that the document must have been totally removed from public files.