Stephan v. United States
Headline: Convicted man’s bid to appeal his federal death sentence directly to the Supreme Court is denied, leaving review of federal capital convictions with the circuit courts.
Holding: The Court denied Stephan’s application for a direct appeal as of right from a district court death sentence, holding that statutes since 1911 withdrew such direct appeals and left review to the circuit courts.
- Denies automatic direct Supreme Court appeals in federal death-penalty cases.
- Leaves review of federal capital convictions to the circuit courts of appeals.
- Vacates any previously granted stay tied to the application for direct appeal.
Summary
Background
A man named Stephan was convicted of treason by a jury in a federal district court and was sentenced to death. He and the trial judge have both sought to have a direct appeal to the Supreme Court allowed under 18 U.S.C. § 681. The Sixth Circuit, sitting en banc, affirmed the conviction (133 F.2d 87), and the Court previously denied review on certiorari (318 U.S. 781; rehearing denied 319 U.S. 783). The application for a direct appeal was presented to Justice Reed and referred to the full Court.
Reasoning
The Court considered whether the statute cited, which on its face seemed to allow direct appeals in death-penalty cases, still authorized appeals directly to this Court. It traced the history: an 1889 law first allowed appeals of capital convictions to the Supreme Court, Congress later created circuit courts of appeals in 1891, and the Judicial Code of 1911 deliberately omitted the earlier clause that had allowed direct appeals in capital cases. The Court explained that appellate jurisdiction comes from statute, that the 1911 change was intentional, and that the surviving language in the current Code cannot override the Statutes at Large. Because the statutes since 1911 do not authorize direct appeals to this Court in capital cases, the application must be denied.
Real world impact
The Court denied Stephan’s request for an automatic direct appeal and vacated the stay that had been granted. As a result, review of federal capital convictions proceeds through the circuit courts of appeals rather than by a direct appeal to the Supreme Court.
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