Darr v. Burford
Headline: State prisoners ordinarily must first ask the Supreme Court to review state denials before federal courts hear habeas claims, limiting district-court habeas access and shifting initial review toward the Supreme Court for many cases.
Holding:
- Requires state prisoners to seek this Court's review before filing federal habeas in district court.
- Limits district courts' ability to hear habeas claims without that prior review.
- Preserves the Supreme Court's primary role in reviewing state criminal judgments.
Summary
Background
A man serving a forty-year state prison term in Oklahoma challenged two armed-robbery convictions and sought collateral relief in the Oklahoma Court of Criminal Appeals in 1947, which denied his habeas petition on the merits. He did not ask the Supreme Court to review that denial and then filed a federal habeas petition in the District Court. The District Court and the Court of Appeals refused to reach the merits because he had not sought review here first.
Reasoning
The Court examined the long history of comity and the exhaustion doctrine. It explained that federal review of state convictions can cause conflict between state and federal courts, and that courts have long required state remedies to be exhausted before federal habeas relief. The Court read Congress’s 1948 habeas statute in light of those precedents and concluded that, ordinarily, a state prisoner should first seek review here before a federal district court will decide the habeas claim on the merits. The Court also recognized rare exceptions when immediate federal action is justified by extraordinary circumstances.
Real world impact
The ruling means many state prisoners must first ask the Supreme Court to review a state court’s refusal of collateral relief before a federal district court will normally consider their habeas claims on the merits. District judges retain discretion to act in truly urgent or exceptional cases, but routine bypass of the Supreme Court is discouraged.
Dissents or concurrances
One Justice concurred except as to inferring reasons from denials; another Justice dissented (joined by two others), arguing denial of Supreme Court review carries no legal weight and district courts should not be barred from hearing exhausted state claims.
Opinions in this case:
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