Michel v. Louisiana

Supreme Court of the United States · 1955 · Federal Courts

Federal CourtsDue ProcessState procedural defaultsGrand jury discrimination claimsFourteenth Amendmentdue processprocedural defaultgrand jury

Facts

Louisiana required objections to the manner of selecting a grand jury to be raised before the expiration of the third judicial day following the end of the grand jury's term, or before trial if sooner, and in any event before arraignment. The petitioners did not challenge their petit juries or the fairness of their trials, but alleged systematic exclusion of Negroes from the grand juries that indicted them. Michel's counsel was appointed in open court on the day the grand jury term expired, yet the motion to quash was not filed until five judicial days later; Poret was a fugitive during the filing period and filed only after return to Louisiana and after arraignment; Labat had appointed counsel with ample time to file but no timely motion was made. Louisiana courts held the claims waived under state law without reaching the merits.

Issue

Whether Louisiana's statutory deadline for challenging grand jury composition, as applied to these petitioners, denied due process under the Fourteenth Amendment by depriving them of a reasonable opportunity to present their federal claim of racial discrimination in grand jury selection.

Rule

A State may attach reasonable time limitations to the assertion of federal constitutional rights, including challenges to discriminatory grand jury selection. The controlling inquiry is whether, in the particular case, the defendant had a reasonable opportunity to have the claimed federal right heard and determined by the state court; if so, failure to comply with the state procedure constitutes waiver.

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

In a Georgia prosecution, state law requires any objection to the composition of the grand jury to be filed no later than the third judicial day after the grand jury term ends and before arraignment. Devon Price was indicted on the last day of the term, and the trial court appointed Maya Benton, a seasoned local defense lawyer, that same day in open court; she filed a one-page motion challenging racial exclusion from the grand jury five judicial days later.

If the state court refuses to hear Devon's constitutional challenge as untimely, which is the strongest argument that the refusal does not violate due process?

Explanation. The majority rule is that a State may impose reasonable time limits on asserting federal constitutional objections, including discriminatory grand-jury-selection claims. The key question is whether the defendant had a reasonable opportunity to have the issue heard and determined in state court. Where experienced counsel is appointed in time to file a short, simple motion, enforcing the deadline does not deny due process.