Brown v. Allen

Supreme Court of the United States · 1953 · Federal Courts

Federal CourtsHabeas CorpusExhaustion of State Remediesfederal habeasstate prisoners28 U.S.C. § 225428 U.S.C. § 2243exhaustion

Facts

The petitioners were North Carolina prisoners convicted in capital cases who sought federal habeas corpus after state-court review ended. Brown challenged alleged racial discrimination in grand and petit jury selection in Forsyth County and the admission of an allegedly involuntary confession. Speller challenged alleged racial discrimination in the selection of a special venire from Vance County, and Daniels challenged jury discrimination, use of confessions, and the state supreme court's refusal to hear the merits of his appeal because his statement of the case on appeal was served one day late. The federal district courts reviewed the state records, and in some cases heard additional evidence, but denied relief.

Issue

Whether state prisoners who have already presented their federal claims on direct review through the highest state court and sought certiorari must still pursue additional state collateral remedies before filing federal habeas, and whether a federal district court must hold a plenary hearing on those federal constitutional claims. Also, whether the particular constitutional claims here justified habeas relief.

Rule

A state prisoner has exhausted available state remedies for purposes of 28 U.S.C. § 2254 when the federal issues have been presented to the highest state court on direct review and certiorari has been denied; repetitive state collateral applications on the same evidence and issues are not required. A federal district court may deny habeas without rehearing facts when the state process has given fair consideration to the issues and evidence and has reached a satisfactory conclusion, unless unusual circumstances call for a hearing. State court determinations are not res judicata on federal constitutional issues, but they are entitled to weight, and where an applicant failed to use an available state remedy without interference or incapacity, federal habeas is barred.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

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

Luis Moreno was convicted in Ohio state court. On direct appeal to the Supreme Court of Ohio, he argued that the prosecutor knowingly used perjured testimony in violation of the Fourteenth Amendment; the court rejected the claim, and the U.S. Supreme Court denied certiorari. Ohio law also allows a post-conviction petition raising the same federal issue on the same trial record.

Before filing a federal habeas petition, must Luis file the state post-conviction petition?

Explanation. The majority held that a state prisoner need not pursue repetitive state collateral remedies when the same federal issues have already been presented to the highest state court on direct review and certiorari has been sought and denied. Exhaustion is satisfied in that circumstance. The denial of certiorari does not itself have conclusive merits effect.