Coleman v. Thompson

Supreme Court of the United States · 1991 · Federal Courts

Federal CourtsHabeas CorpusProcedural DefaultIndependent and Adequate State Groundsfederal habeasprocedural defaultstate procedural barindependent and adequate state ground

Facts

Coleman was convicted in Virginia of rape and capital murder and sentenced to death. After his direct appeal failed, he filed a state habeas petition raising several federal constitutional claims, but after the trial court denied relief, his notice of appeal to the Virginia Supreme Court was filed 33 days after final judgment rather than within the 30 days required by Virginia Supreme Court Rule 5:9(a). The Virginia Supreme Court granted the Commonwealth's motion to dismiss the appeal, a motion based solely on untimeliness. Coleman then sought federal habeas relief, including claims that had been raised for the first time in state habeas.

Issue

Whether federal habeas review was barred when the Virginia Supreme Court dismissed Coleman's state habeas appeal as untimely under a state procedural rule, and whether attorney error in that state collateral appeal constituted cause to excuse the default. The case also asked whether the Harris v. Reed plain-statement presumption applied to the Virginia Supreme Court's summary dismissal order.

Rule

When a state prisoner has defaulted federal claims in state court pursuant to an independent and adequate state procedural rule, federal habeas review is barred unless the prisoner shows cause for the default and actual prejudice, or shows that failure to consider the claims will result in a fundamental miscarriage of justice. The Harris/Long plain-statement presumption applies only when the last state-court decision fairly appears to rest primarily on federal law or to be interwoven with federal law. Attorney error in state postconviction proceedings cannot constitute cause where there is no constitutional right to counsel in those proceedings.

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

After his conviction in Ohio became final, Devin Mercer filed a state postconviction petition raising a federal Confrontation Clause claim for the first time. The state trial court denied relief, and Mercer filed his notice of appeal 12 days late under a mandatory Ohio appellate rule. The Ohio Supreme Court then entered a short order granting the State's motion to dismiss the appeal, and that motion relied only on untimeliness.

In Mercer's later federal habeas action, what is the strongest argument about review of the Confrontation Clause claim?

Explanation. When a state prisoner defaults a federal claim pursuant to an independent and adequate state procedural rule, federal habeas review is barred unless the prisoner shows cause and actual prejudice or a fundamental miscarriage of justice. The majority made clear that this rule applies to all such defaults, including default of an entire appeal, and rejects Fay's deliberate-bypass standard in this setting.