Rezin v. Wolff, Warden

1979-01-15

Headline: Court declines to review a Nevada convict’s claim that his plea bargain was breached, leaving the state-court rejection in place and blocking immediate federal review of the Santobello issue.

Holding: The Court denied the petition for review, leaving the Nevada Supreme Court’s rejection of the petitioner’s Santobello-based plea-bargain breach claim in place and refusing federal review.

Real World Impact:

Leaves the Nevada court’s rejection of the plea-bargain claim in place
Denies federal review of this plea-bargain dispute, keeping conviction intact
Dissent says the Court should have reviewed the Santobello issue

Topics: plea bargains, prisoners' appeals, state court decisions, federal review

Summary

Background

Daniel Roy Rezin, a man convicted in Nevada, claimed his plea bargain had been breached and the Nevada Supreme Court rejected that claim. He then sought federal relief, but the federal district court denied his habeas petition because he first raised the Santobello plea-bargain issue on appeal rather than at trial. The Ninth Circuit affirmed the denial, and Rezin asked this Court to review the case.

Reasoning

The Court declined to grant review and simply denied the petition for a writ of review. Justice White, joined by Justices Brennan and Marshall, dissented. He argued that the earlier Wainwright v. Sykes decision did not create its own rule requiring objections at trial apart from state rules, and that the Nevada Supreme Court had in fact reached and decided the Santobello plea-bargain question—so there was no independent state procedural bar preventing this Court from considering the claim.

Real world impact

Because the Court refused to hear the case, the Nevada court’s rejection of the plea-bargain claim remains in place and Rezin’s conviction stands for now. The decision is a procedural refusal to review rather than a ruling on whether the plea bargain was actually breached, so the question could still be relitigated later or in a different case. The ruling affects how and when similar plea-bargain complaints may get federal attention.

Dissents or concurrances

The dissenting opinion says the federal courts should have reviewed the Santobello claim because the state court decided the issue on its merits and Sykes therefore does not bar Supreme Court review.