Patterson v. Alabama
The Supreme Court vacated Haywood Patterson's death sentence and sent his case back to the Alabama Supreme Court, after that court had struck his appeal papers as untimely while, on the very same day, ruling for his co-defendant Clarence Norris on the identical claim that Black citizens were unconstitutionally excluded from Alabama juries.
Because Patterson had raised the same constitutional challenge using the same evidence as Norris, the Court found the timing and circumstances too unusual to let a procedural technicality stand without giving Alabama's courts a chance to reconsider in light of the Norris ruling.
“It is always hazardous to apply a judicial ruling, especially in a matter of procedure, to a serious situation which was not in contemplation when the ruling was made.”
Explaining why the Court would not let a routine procedural rule decide a case with such unusual stakes.
How it got here: Alabama's Supreme Court struck Patterson's bill of exceptions as untimely and affirmed his conviction without reaching his jury-discrimination claim; he sought Supreme Court review.
The Case in Depth
What happened
Haywood Patterson, one of the "Scottsboro Boys," was indicted with Clarence Norris and seven other Black teenagers in Jackson County, Alabama, for rape. His first two convictions were undone (one by this Court in Powell v. Alabama, one by the trial judge), and he was convicted a third time in November 1933 and sentenced to death. He argued Black residents had been systematically excluded from grand and trial juries in the counties involved.
The question before the Court
Could Alabama uphold a Scottsboro defendant's death sentence by refusing to hear his appeal on a filing-deadline technicality, right after ruling for his co-defendant on the same evidence that Black jurors had been illegally excluded?
Why it matters
A man sentenced to death by an all-white jury system got another chance at appellate review, instead of losing his case purely on a paperwork deadline while his co-defendant, tried on identical evidence, won on the merits. The ruling shows the Supreme Court will step in when state procedural rules produce starkly inconsistent results in closely linked capital cases.
What changes now
The judgment is vacated, not affirmed or finally decided on the merits, and the case goes back to the Alabama Supreme Court so it can reconsider, in light of its companion ruling in Norris's case, whether to excuse the late filing and reach Patterson's jury-discrimination claim. The federal constitutional question about jury exclusion itself was resolved in the companion Norris decision issued the same day.
What this does not decide
The Court did not rule on whether Black jurors were unconstitutionally excluded in Patterson's own case — that constitutional question had been decided in the companion Norris case. This decision only addresses whether the state court's procedural dismissal of Patterson's appeal should stand given the unusual circumstances.
Concurrences and dissents
How the Justices voted
Majority (1). Justice Hughes (author).
How the Court got there
The legal reasoning, step by step
- The Court first had to decide whether it even had power to review the case, since a state court's ruling resting entirely on an independent, adequate state procedural ground normally cannot be reviewed for a federal constitutional violation. The Court examined the record to see whether that was really what happened here.
- The Court accepted that Alabama's rule for counting the ninety-day deadline for filing a bill of exceptions (the formal record of trial objections needed for appeal) from the date of the guilty verdict, rather than from the later sentencing date, was a long-established state rule the state court could apply without violating any federal right.
- But Alabama's own statute said a state appellate court could not strike a bill of exceptions as untimely on its own initiative — it could only do so if a party specifically asked, and only after the other side had a chance to waive the objection by not raising it.
- The Court noted the highly unusual circumstances: Patterson's case relied on the identical evidence and claim as Norris's case, decided by the same court on the same day; the Attorney General had once described the judgment date in a way that, if accurate, would have made Patterson's filing timely; and the state court ruled against Norris's jury-discrimination claim on the merits.
- Because the state court might well have handled the timeliness question differently had it already known its own constitutional ruling in Norris would come out the way it did, the Court held that fairness required giving the state court a fresh opportunity to reconsider its procedural ruling in light of that outcome, rather than treating the case as finally closed on a technicality.
Doctrinal impact
Cases affected by this decision
Reaffirms Powell v. Alabama (287 U. S. 45)
The Court notes it had already reversed Patterson's and the other defendants' earlier convictions in this decision.