New York Ex Rel. Whitman v. Wilson
Headline: Vacates and remands a prisoner’s due-process challenge alleging perjured testimony, sending the question whether New York allows habeas relief or requires a coram nobis motion back to state courts.
Holding: The Court vacated its judgment and remanded the case so New York courts can decide whether state law allows habeas corpus review or instead requires a coram nobis motion to raise the perjury claim.
- Sends procedural question about habeas vs coram nobis back to New York courts.
- Delays federal resolution of the prisoner’s due-process claim.
- Affects other New York prisoners seeking post-conviction relief for perjury-based claims.
Summary
Background
A person convicted in New York applied for a writ of habeas corpus, saying the conviction relied on prosecution-used perjured testimony and so violated his right to due process under Mooney v. Holohan. New York trial and intermediate appellate courts denied relief, and higher state review was limited. This Court granted review and appointed counsel after the petitioner said state courts had wrongly denied a hearing on his claim.
Reasoning
After the Supreme Court accepted the case, New York’s Court of Appeals decided Lyons v. Goldstein, holding that the trial court can set aside a conviction obtained by fraud through a coram nobis-type proceeding and that due process requires a hearing on such claims. Because Lyons changed the state-law landscape, the Supreme Court said it could not finally decide whether New York law allows habeas corpus in this situation. The Court therefore vacated its prior disposition and remanded the case for the state courts to apply Lyons and decide the proper state remedy.
Real world impact
The ruling sends the procedural question back to New York courts rather than resolving the prisoner’s constitutional claim on federal grounds. That means the petitioner and other New York prisoners alleging perjured testimony must await the state courts’ choice of remedy before the federal courts will consider the merits. The decision does not resolve whether the conviction was unlawfully obtained.
Dissents or concurrances
Justice Frankfurter, joined by Justices Roberts and Reed, said petitioner chose the wrong procedure under New York law and that habeas corpus is not the proper remedy under §1231; he would dismiss the petition as not properly presented to the state courts.
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