Hunter v. Tennessee

Background

A group of people convicted of rape after a joint trial in Tennessee were sentenced to death. While their appeals were pending in the Tennessee Supreme Court, the U.S. Supreme Court announced its decision in Witherspoon v. Illinois. The defendants attempted to add new issues under Witherspoon to their bills of exceptions, but an older Tennessee law barred filing those bills more than 90 days after judgment. The Tennessee Supreme Court affirmed without addressing Witherspoon. While the cases were pending here, Tennessee amended the law to allow appellate courts to order filing of bills of exceptions at any time for good cause.

Reasoning

The core question was whether the federal Court should disturb the state judgments to allow the defendants to use the new Tennessee law to supplement their trial records. The Court granted motions to proceed without fees, granted review, vacated the state-court judgments, and sent the cases back to the Tennessee Supreme Court so the defendants could apply under the amended statute for leave to supplement their bills of exceptions. The Court explicitly said it was not deciding the merits of the defendants’ claims or whether the amended Tennessee statute applies to these cases.

Real world impact

The ruling gives the convicted people a renewed procedural chance in state court to seek additions to their trial records that could raise Witherspoon-related issues. The decision does not resolve whether those issues will succeed on the merits. Because the Court only vacated and remanded for state-court consideration, the final outcome remains uncertain and depends on how the Tennessee Supreme Court applies the new law.

Dissents or concurrances

One Justice, Black, dissented; the per curiam opinion records his dissent but does not state his reasons.