Baldwin v. Reese

Supreme Court of the United States · 2004 · Federal Courts

Federal CourtsHabeas CorpusExhaustion of State RemediesFair Presentation28 U.S.C. § 2254exhaustionfair presentationfederal habeas

Facts

Reese challenged his Oregon convictions and later pursued state collateral relief. In his petition for discretionary review to the Oregon Supreme Court, he asserted ineffective assistance of both trial and appellate counsel, and he identified federal constitutional provisions for the trial-counsel claim, but not for the appellate-counsel claim. He later filed a federal habeas petition alleging a federal constitutional ineffective-assistance-of-appellate-counsel claim. The Ninth Circuit concluded the claim had been fairly presented because the Oregon Supreme Court could have discovered its federal nature by reading the lower court opinion.

Issue

Whether a state prisoner fairly presents a federal claim to a state court for exhaustion purposes when the petition or brief itself does not alert the court to the federal nature of the claim, but the court could discover that nature by reading a lower court opinion in the case. Also, whether Reese's petition itself sufficiently alerted the Oregon Supreme Court that his ineffective-assistance-of-appellate-counsel claim was federal.

Rule

To satisfy § 2254 exhaustion, a prisoner must fairly present the federal nature of his claim in each appropriate state court, including a state supreme court with discretionary review. Ordinarily, a claim is not fairly presented if the state court must read beyond the petition, brief, or similar document that fails to alert it to the presence of a federal claim in order to find material, such as a lower court opinion, that does so.

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

After losing postconviction proceedings in Ohio, Darnell Price files a memorandum seeking discretionary review in the Ohio Supreme Court. His memorandum argues that the trial court admitted coerced statements and cites only Ohio evidentiary cases, but the court of appeals opinion below discussed the issue under the Fifth Amendment.

If Darnell later files a federal habeas petition asserting a federal self-incrimination claim, has he ordinarily fairly presented that federal claim to the Ohio Supreme Court?

Explanation. A prisoner must fairly present the federal nature of the claim in each appropriate state court, including a court of discretionary review. Ordinarily, fair presentation is not satisfied when the petition or brief itself does not alert that court to the federal basis and the court would have to read lower court opinions or other materials to find it.