Stembridge v. Georgia

Background

A man was convicted of voluntary manslaughter for shooting an eighteen-year-old woman; a second woman was wounded. He claimed self-defense, but a jury convicted him. After appeals in Georgia failed, he filed a post-trial motion saying he had newly discovered evidence: ten jurors signed affidavits saying they would have voted not guilty if they had seen a hospital statement by the wounded woman that conflicted with her trial testimony. The police had kept a copy of that hospital statement, and Georgia courts treated the material as impeachment evidence and denied a new trial.

Reasoning

The key question was whether this Court should review the state courts’ handling of the new-evidence and constitutional claims. The petitioner raised federal due process and equal protection arguments for the first time on rehearing in the Court of Appeals. The Georgia courts either did not rule on those federal questions or could have rested their rulings on state-law grounds. The Supreme Court concluded that when it is debatable whether a state’s highest court relied on an adequate state-law ground, the Supreme Court lacks clear authority to decide the federal claim. Because that possibility remained, the Court said its grant of review was improvident and dismissed the case.

Real world impact

The dismissal leaves the Georgia conviction and the state courts’ rulings in place without a federal decision on the merits. It emphasizes that federal constitutional claims should be raised and resolved in state courts first, or the Supreme Court may refuse to intervene. The ruling does not decide guilt or innocence.

Dissents or concurrances

One Justice concurred in the judgment but would have affirmed the Georgia courts; three Justices dissented from the dismissal.