Garrison v. Patterson

Background

A man convicted of first-degree murder in Colorado in 1959 was sentenced to death and later sought relief in federal court by asking to set aside his conviction. The federal trial court denied his petition for habeas corpus in June 1967, refused a certificate of probable cause to appeal, but granted a short stay of execution. His lawyers filed a three-page request for a longer stay, a certificate allowing appeal, and permission to proceed without fees. After an unrecorded oral hearing, the Court of Appeals granted the certificate and then affirmed the denial without further written argument.

Reasoning

The Supreme Court reviewed whether the Court of Appeals denied the convicted man a real chance to argue the merits after granting permission to appeal. The Court relied on earlier decisions saying that when a court allows an appeal, the person must be given an opportunity to address the underlying issues. The Court said appeals courts may use summary procedures, but if they do they must warn the person that the opportunity to argue will be limited. The Court vacated the appeals court’s judgment and sent the case back for further proceedings consistent with these rules, and it continued the stay of execution while the appeals court acts.

Real world impact

This ruling affects people who win permission to appeal criminal convictions, including death-row prisoners, by ensuring they can present full arguments on the merits. It requires courts of appeals to adopt or announce procedures that let applicants know whether their opportunity to argue will be restricted. The decision may mean more briefing or hearings before appeals are finally decided and can temporarily delay final punishments while appeals proceed.