Herrera v. Collins

Supreme Court of the United States · 1993 · Criminal Law

Criminal LawFederal Habeas CorpusActual InnocenceDeath PenaltyDue ProcessEighth Amendmentfederal habeasactual innocence

Facts

Herrera was convicted of the capital murder of Officer Carrisalez and sentenced to death, and he later pleaded guilty to the murder of Officer Rucker. At trial, the State presented eyewitness identifications, evidence connecting Herrera to the car used in the shootings, physical evidence linking him to Rucker's killing, and a handwritten letter strongly implying that he had killed Rucker. About eight years later, Herrera presented affidavits asserting that his now-dead brother Raul, Sr., had confessed to committing the murders and that Herrera was not the killer. Herrera sought federal habeas relief based on this newly discovered evidence, arguing that executing an innocent person would violate the Constitution.

Issue

Whether a state prisoner may obtain federal habeas relief based solely on a freestanding claim of actual innocence supported by newly discovered evidence, without identifying an independent constitutional violation in the underlying state criminal proceeding. Also, whether Herrera's showing of innocence entitled him to relief under the Eighth or Fourteenth Amendments.

Rule

Claims of actual innocence based on newly discovered evidence have never been held to state a ground for federal habeas relief absent an independent constitutional violation in the underlying state criminal proceeding. Actual innocence is not itself a constitutional claim, but a gateway through which a habeas petitioner may pass to have an otherwise barred constitutional claim heard; and even assuming arguendo that, in a capital case, a truly persuasive post-trial demonstration of actual innocence might render execution unconstitutional if no state avenue existed, the threshold showing would be extraordinarily high.

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

Darius Cole was convicted of murder in Georgia after a jury trial and sentenced to life in prison. Nine years later, he files a federal habeas petition supported by two new affidavits stating that another man confessed to the killing; he alleges no trial error, suppression of evidence, or other constitutional defect in the state proceedings.

Should the federal court grant habeas review on the basis of Darius's innocence claim alone?

Explanation. The majority held that claims of actual innocence based on newly discovered evidence have never been held to state a ground for federal habeas relief absent an independent constitutional violation in the underlying state criminal proceeding. Federal habeas courts do not sit to correct mere factual errors or relitigate guilt based solely on new evidence.