Williams v. Georgia

Supreme Court of the United States · 1955 · Federal Courts

Federal Courtsadequate and independent state groundstate procedural defaultfederal jurisdictiondiscretionary state remediesequal protectionjury discriminationextraordinary motion for new trial

Facts

Williams, a Negro, was convicted of murdering a white man in Fulton County, Georgia, and sentenced to death. The petit jury pool for his trial was drawn using white tickets for white persons and yellow tickets for Negroes; of 120 jurors available for the week, four were Negroes, and none ultimately served on Williams' jury. Williams did not challenge the array at trial, but later filed an extraordinary motion for new trial alleging that he had been denied equal protection by the manner in which the jury was selected, organized, impaneled, and challenged. Before the Supreme Court of the United States, the State agreed that, in light of Avery v. Georgia, the use of yellow and white tickets denied equal protection, absent waiver.

Issue

Whether the Georgia Supreme Court's refusal to entertain Williams' late-raised equal protection challenge rested on an adequate nonfederal ground that deprived the Supreme Court of jurisdiction. If jurisdiction existed, whether the proper disposition was immediate relief or remand to the Georgia Supreme Court for further consideration.

Rule

A state procedural rule requiring federal constitutional objections to be raised at a prescribed time or by a prescribed method is generally valid. But when state law permits such objections to be raised at a late stage through a discretionary procedure, the Supreme Court is not barred from examining whether the state court's refusal to entertain the claim in the particular circumstances is, in effect, an avoidance of the federal right; a state court may not, in the exercise of discretion, decline to entertain a constitutional claim while entertaining kindred issues raised in the same manner.

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

In Columbus, Ohio, Devon Price was convicted of armed robbery. Ohio law generally requires objections to jury-selection procedures before the jury is sworn, but it also authorizes a rarely granted post-appeal "extraordinary reopening" in exceptional cases; Ohio courts have previously used that procedure to consider serious juror-irregularity claims. Devon first raises a federal equal protection challenge to the jury-selection system in that extraordinary proceeding, and the state supreme court refuses relief on the ground that he should have raised it earlier.

If Devon seeks review in the U.S. Supreme Court, which is the best analysis?

Explanation. The majority rule is that an ordinary state timing rule is generally valid, but when state law permits the late assertion of the federal claim through a discretionary procedure, the Supreme Court is not barred from examining whether the refusal to hear the claim effectively avoids the federal right. The key is that the state court possessed power to entertain the claim, not that it actually reached the merits.