Patterson v. Alabama

Supreme Court of the United States · 1935 · Federal Courts

Federal Courtsstate procedural groundbill of exceptionsvacaturremandfederal constitutional questionjury discriminationadequate non-federal ground

Facts

Patterson was indicted with Clarence Norris and others for rape, and after an earlier reversal by the U.S. Supreme Court he was retried and again convicted. At the third trial, Patterson moved to quash both the indictment and the trial venire on the ground that qualified Black citizens had been systematically excluded from jury service because of race. The evidence on those motions was later stipulated to be the same evidence used in Norris's companion case. On appeal, the Alabama Supreme Court struck Patterson's bill of exceptions as untimely and therefore did not consider the federal constitutional question.

Issue

Whether the Alabama Supreme Court's affirmance rested on a non-federal state procedural ground that deprived the U.S. Supreme Court of any further power to act, or whether this Court could vacate and remand in light of the constitutional ruling in the companion Norris case and the unusual circumstances surrounding the state procedural ruling.

Rule

Although a state court may apply its own procedural rules without violating federal rights, the U.S. Supreme Court may, in the exercise of its appellate jurisdiction, vacate a judgment and remand when justice so requires because a supervening change in fact or law may affect the proper disposition of the case. Doing so does not review the state court's non-federal ruling as such, but permits the state court to reconsider its powers and provide appropriate relief in light of the changed situation.

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

In Richmond, Virginia, Leon Carter was convicted in state court. The Virginia Supreme Court refused to consider his equal-protection challenge because his trial transcript was filed late under a state appellate rule. The same day, the U.S. Supreme Court decided a companion case brought by Leon's codefendant, holding that the identical constitutional claim was valid on materially identical evidence introduced at the two trials.

What is the most appropriate action for the U.S. Supreme Court if it concludes the companion decision may affect the proper disposition of Leon's case?

Explanation. The majority recognized that a state court may enforce its own procedural rule, yet the U.S. Supreme Court may still vacate and remand when a supervening development in law or fact bears on the right disposition of the case. That disposition does not directly review the non-federal procedural ruling; it gives the state court an opportunity to examine its powers and provide appropriate relief in light of the changed situation.