Whitney v. Florida

Background

The case involves a man convicted of a particularly brutal murder during an armed robbery, who at trial entered a written stipulation effectively confessing and received the death sentence. He later claimed that wide pretrial publicity, including television broadcasts of his confessions, prevented a fair jury and that his trial lawyer refused his request for a change of venue. He sought collateral review in Florida courts, which rejected his claims and did not hold an evidentiary hearing.

Reasoning

The Supreme Court was asked whether Florida’s summary dismissal of the collateral attack, without an evidentiary hearing, violated the Constitution. The Court declined to reach the merits and dismissed the writ as improvidently granted, saying the defendant may apply for a federal habeas corpus petition in the appropriate U.S. District Court. In dissent, one Justice said the State, having provided a review procedure, should have given an evidentiary hearing because the allegations showed a strong enough claim; another Justice would have affirmed the state court, viewing counsel’s choices as tactical and finding no basis for federal intervention.

Real world impact

As a result, the Supreme Court gave no immediate relief and left the state conviction in place while explicitly allowing the defendant to seek federal habeas review in district court. The opinions show a sharp dispute about when states must provide evidentiary hearings for collateral claims and whether federal courts should step in. The differing views highlight tensions over counsel strategy, pretrial publicity, and the burden on federal habeas procedures.

Dissents or concurrances

The dissents matter: one would vacate and send the case back for a hearing, the other would discourage further federal habeas review and affirm the state decision.