Slayton v. Smith

Background

A man in state custody filed a federal petition saying he had been tried and sentenced by a senile judge. The federal district court dismissed his petition without a hearing. On appeal, the Fourth Circuit said the man had not yet used state court remedies, expressed confidence the state courts would hear the claim, but ordered the federal court to keep the case on its docket while the man sought relief in Virginia state courts.

Reasoning

The Supreme Court reviewed whether the appeals court handled an unexhausted federal challenge properly. The Court noted a federal statute bars federal courts from granting such petitions before state remedies are tried. It explained that once an appeals court finds state remedies unused, it should avoid implying anything about the merits of a sensitive claim. Except in unusual situations, the proper course is to vacate the lower judgment and dismiss the federal petition instead of retaining the case on the federal docket.

Real world impact

The ruling affects prisoners seeking federal review of their state convictions by emphasizing that federal courts should not keep cases open when state procedures have not been used first. It discourages federal courts from making any comments that could be read as judging the claim’s substance. This decision is procedural, not a final ruling on whether the man’s claim about the judge’s fitness is true, and the case returns to the appeals court for action consistent with the opinion.

Dissents or concurrances

Two Justices would have affirmed the appeals court, believing it followed the statute and proper procedures, and would have left the Fourth Circuit’s approach in place.