Cardinale v. Louisiana

Supreme Court of the United States · 1969 · Federal Courts

Federal CourtsSupreme Court jurisdictionstate-court review28 U.S.C. § 1257preservationfederal questionconstitutional claimadequate record

Facts

Petitioner confessed to Tucson, Arizona police after surrendering while fleeing Louisiana following a murder near New Orleans. At his later murder trial, the confession was introduced in its entirety, and petitioner was convicted and sentenced to death. Petitioner did not contend that the confession was involuntary or that his admission of guilt was inadmissible. Instead, he argued that parts of the confession were irrelevant and prejudicial and that the Louisiana statute requiring entire confessions to be admitted was unconstitutional.

Issue

May the Supreme Court decide a federal constitutional challenge to a state statute on review of a state-court judgment when the petitioner did not raise, preserve, or obtain a ruling on that federal issue in the state courts below?

Rule

On review of state-court judgments, the Supreme Court will not decide a federal constitutional issue raised for the first time in this Court. Its appellate jurisdiction under 28 U.S.C. § 1257 fails unless the federal question was raised and decided in the state court below.

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In Portland, Oregon, Elena Ruiz was convicted in state court of fraud. In the Oregon appellate courts, she argued only that the trial judge misapplied Oregon evidence law, but in her petition to the U.S. Supreme Court she argues for the first time that the evidentiary ruling violated the Due Process Clause.

May the U.S. Supreme Court decide Elena's due process claim on direct review of the state-court judgment?

Explanation. The Court's appellate jurisdiction under 28 U.S.C. § 1257 does not extend to a federal constitutional issue raised for the first time in the Supreme Court. Under the majority opinion, the federal question must appear on the record as having been raised in the state court and passed upon there. Because Elena argued only state-law error below, the Court could not reach the federal due process claim.