Swain v. Pressley

Supreme Court of the United States · 1977 · Federal Courts

Federal CourtsHabeas CorpusSuspension ClauseD.C. Court Reform ActCollateral Review28 U.S.C. § 2255D.C. Code § 23-110(g)inadequate or ineffective

Facts

Congress enacted D.C. Code § 23-110 as part of the District of Columbia Court Reform and Criminal Procedure Act of 1970, creating a local postconviction remedy in the Superior Court comparable to 28 U.S.C. § 2255. Section 23-110(g) states that a habeas application by a prisoner eligible to seek relief by motion under that section shall not be entertained by any federal or state court if the prisoner has failed to seek local relief or if the Superior Court has denied relief, unless the motion remedy is inadequate or ineffective to test the legality of detention. Respondent had pursued local postconviction remedies and then filed a federal habeas application in District Court. The legal dispute concerned whether § 23-110(g) merely required exhaustion or instead barred the District Court from entertaining the petition, and whether such a bar was constitutional.

Issue

Does D.C. Code § 23-110(g) bar the federal District Court from entertaining a habeas petition by a prisoner sentenced in the D.C. Superior Court after local collateral relief has been denied, unless the local remedy is inadequate or ineffective? If so, does that arrangement suspend the writ of habeas corpus in violation of Article I, § 9, cl. 2?

Rule

Section 23-110(g) must be read according to its plain terms to preclude federal habeas review for prisoners authorized to seek relief under § 23-110 when they have not used that remedy or have been denied relief, unless the § 23-110 remedy is inadequate or ineffective to test the legality of detention. The substitution of a collateral remedy that is neither inadequate nor ineffective does not constitute a suspension of the writ of habeas corpus.

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Jordan Pike is serving a sentence imposed by the Superior Court of the District of Columbia. He files a habeas petition in the United States District Court for the District of Columbia alleging that his conviction violated the Sixth Amendment, but he never filed a motion under the local postconviction statute that authorizes the Superior Court to vacate or correct its own judgments.

How should the federal district court rule?

Explanation. The majority read the statute according to its plain terms: if a prisoner is authorized to seek relief by motion in Superior Court, a federal court shall not entertain habeas if the prisoner failed to use that remedy or if Superior Court denied relief, unless the motion remedy is inadequate or ineffective to test the legality of detention. The bar is not merely an exhaustion rule. (Derived from Swain v. Pressley (n.d.).)