Pitchess v. Davis
Headline: Court limits federal habeas relief when defendants raise new claims about destroyed evidence without first using state courts, reversing a Ninth Circuit order that blocked retrial and requiring state remedies be exhausted.
Holding:
- Requires defendants to raise new trial claims in state courts before federal habeas review.
- Prevents federal courts from making unconditional orders on unexhausted claims.
- Allows state retrials to proceed while defendants pursue state appellate review.
Summary
Background
A man convicted in 1967 of rape, kidnaping, and oral copulation in Los Angeles challenged his conviction after learning that the prosecutor had not turned over a lab report showing no sperm. He won a conditional federal habeas writ in 1972; the lab report was then given to him. When he asked for the victim’s vaginal slides and clothing, he learned that police routine had destroyed those items during the six years since his conviction became final. State courts denied his pretrial efforts to block retrial, and a federal district court later converted its conditional writ to an absolute order because it concluded the destroyed evidence made a fair retrial impossible. The Ninth Circuit affirmed that decision.
Reasoning
The Court addressed whether a federal habeas court may grant relief based on a new claim that was never first raised in state court. Relying on the federal habeas statute, the Court held that exhaustion of available state remedies is required and that denial of extraordinary pretrial writs without opinion did not exhaust state review. The Court also explained that a general civil rule (Rule 60(b)) cannot override the statute. Because the destroyed-evidence claim had not been presented to the state courts, the federal courts could not grant unconditional relief based on that claim and could not maintain continuing supervision over the retrial.
Real world impact
The Court reversed the Ninth Circuit and directed the district court to vacate the orders entered after the conditional writ. The decision does not decide whether the destroyed evidence would have proved innocence; instead it requires the defendant to pursue available state procedures first and preserves the State’s ability to retry while state appellate review remains available.
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