Supreme Court of the United States · 1976 · Federal Courts
428 U.S. 465 (1976)
Updated
Federal CourtshabeasFourth Amendment claims28 U.S.C. § 2254habeas corpusFourth Amendmentexclusionary rulefull and fair opportunity
Facts
Both respondents were convicted in state court, and evidence allegedly obtained through unconstitutional searches or seizures was introduced at trial. Powell challenged testimony about a revolver found on him after a Nevada arrest under a Henderson vagrancy ordinance; Rice challenged evidence seized from his home and derivative evidence after Nebraska police searched his residence under a warrant later found invalid by the federal district court. Each respondent had presented his Fourth Amendment claim in state court and later sought federal habeas relief under § 2254. The Supreme Court addressed whether federal habeas courts should reconsider such claims after the state courts had afforded an opportunity for full and fair litigation.
Issue
May a federal court grant habeas relief to a state prisoner on the ground that evidence obtained in an unconstitutional search or seizure was introduced at trial when the prisoner already had an opportunity for full and fair litigation of that Fourth Amendment claim in the state courts?
Rule
Where the State has provided an opportunity for full and fair litigation of a Fourth Amendment claim, a state prisoner may not be granted federal habeas corpus relief on the ground that evidence obtained in an unconstitutional search or seizure was introduced at trial.
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In Phoenix, Nolan Reyes was convicted in Arizona state court after police found stolen jewelry in his apartment. Before trial, he moved to suppress under the Fourth Amendment, lost after an evidentiary hearing, raised the issue again on direct appeal, and then filed a federal habeas petition under 28 U.S.C. § 2254 arguing the search was unconstitutional and the evidence should have been excluded.
How should the federal habeas court rule?
Explanation. The majority held that where the State has provided an opportunity for full and fair litigation of a Fourth Amendment claim, a state prisoner may not be granted federal habeas relief on the ground that illegally obtained evidence was introduced at trial. The bar turns on the opportunity for full and fair litigation, not on whether the state courts reached the correct result. The Court also indicated this is not a pure jurisdictional defect; rather, the exclusionary rule need not be applied on habeas in that setting.