Wainwright v. Stone

Supreme Court of the United States · Criminal Law

Criminal LawVoid for VaguenessFederal Habeas CorpusState Statutory Constructionvoid for vaguenessfair noticestate court constructionhabeas corpus

Facts

In separate trials, appellees were convicted under Fla. Stat. § 800.01, which proscribed "the abominable and detestable crime against nature, either with mankind or with beast." Stone was convicted for copulation per os and per anum, and Huffman for copulation per anum. Before their conduct and convictions, Florida decisions had long construed § 800.01 and its predecessor statutes to cover those acts, including Ephraim v. State and Delaney v. State. After appellees' convictions became final, the Florida Supreme Court in Franklin v. State held the statute void for vagueness as to oral and anal sexual activity, but made that ruling prospective only.

Issue

Whether Fla. Stat. § 800.01 was unconstitutionally vague as applied to appellees' pre-Franklin convictions, despite prior Florida decisions construing the statute to cover the conduct for which they were convicted. More specifically, the question was whether federal courts could disregard those prior state-court constructions when assessing fair notice.

Rule

For purposes of deciding whether a state criminal statute is impermissibly vague, a federal court must assess the statute as authoritatively construed by the state's highest court. When prior state decisions have made particular conduct identifiable as prohibited, those constructions supply the required notice and are treated as though written into the statute itself.

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In Ohio, a criminal statute makes it a felony to engage in a "grossly indecent act." For more than 20 years before Nolan Price was charged in Cleveland, the Ohio Supreme Court had repeatedly held that the phrase includes secretly recording people while they undress in a locker room. Nolan argues in federal habeas that the statute is facially void for vagueness because the text does not specifically mention video recording.

How should the federal court rule on Nolan's vagueness claim?

Explanation. The governing rule is that a vagueness challenge to a state criminal statute is assessed in light of prior authoritative constructions by the state's highest court. Those constructions are treated as if written into the statute itself. Because the Ohio Supreme Court had already made Nolan's conduct identifiable as prohibited, he had adequate notice even if the bare text was general. (Derived from Wainwright v. Stone (n.d.).)