Kindler v. Horn

United States Court of Appeals for the Third Circuit · 2008 · Federal Courts

Federal CourtsHabeas CorpusProcedural Defaulthabeasprocedural defaultfugitive forfeiture ruleadequate state groundindependent state ground

Facts

Joseph J. Kindler sought federal habeas relief. The Commonwealth argued that his claims were procedurally defaulted under Pennsylvania's fugitive forfeiture rule. The district court rejected that argument in part by relying on Doctor v. Walters, where the Third Circuit had held that Pennsylvania's fugitive forfeiture rule was not firmly established when Doctor escaped in 1986. Based on that understanding, the district court concluded the fugitive forfeiture rule did not provide an independent and adequate basis to bar federal review of Kindler's habeas claims.

Issue

Whether Pennsylvania's fugitive forfeiture rule provided an independent and adequate state procedural ground sufficient to preclude federal habeas review of Kindler's claims.

Rule

A state procedural rule bars federal habeas review only if it constitutes an independent and adequate state ground; a rule that was not firmly established at the relevant time is not adequate for that purpose.

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

In federal habeas proceedings in Philadelphia, Andre Molina challenges his state murder conviction. The state argues his claims are barred by a Pennsylvania procedural rule that state courts invoked after he fled during post-trial proceedings, but the record shows the rule had not been firmly established at the time of his flight.

Should the federal court treat the state rule as an adequate ground barring habeas review?

Explanation. Federal habeas review is barred only by an independent and adequate state ground. Under the majority opinion, a state rule that was not firmly established at the relevant time is not adequate. (Derived from Kindler v. Horn (n.d.).)