Wainwright v. Stone

Background

Two men convicted under an old Florida law banning “the crime against nature” challenged their convictions in federal court, saying the law was too vague to give fair notice. One man was convicted for both oral and anal sex and the other for anal sex. A federal court granted relief and the Court of Appeals held the statute void for vagueness on its face, which would have undone their convictions.

Reasoning

The Court asked whether the men could reasonably understand the law forbade their conduct at the time they acted. It relied on earlier Florida decisions that had long treated oral and anal intercourse as falling within the statute, so the law as previously interpreted gave clear notice. A later Florida decision that questioned the statute’s clarity was expressly applied only going forward, not to past convictions. The Supreme Court emphasized that federal courts must respect how a state’s highest court had already interpreted its law and therefore reversed the Court of Appeals.

Real world impact

Because the state court had earlier interpreted the statute to include oral and anal sex, the men’s convictions stood. The ruling means people convicted before the Florida decision that narrowed the law are generally not entitled to relief based on that later change. The opinion also instructs federal courts to evaluate vagueness claims in light of prior state court meanings, which shapes how similar challenges will be reviewed.