Spalding Et Al. v. Aiken

Background

Arthur Aiken, a man convicted of three 1965 murders in Washington and originally sentenced to death, was resentenced to three consecutive life terms after appeals. Fourteen years after his original conviction and eight years after resentencing, he filed a federal habeas petition raising claims that had been litigated a decade earlier. The State said the long delay harmed its ability to retry because many witnesses and nearly all exhibits were gone.

Reasoning

The Supreme Court declined to review the case (certiorari denied). In a separate statement, the Chief Justice argued that federal habeas relief should be limited for very late claims. He said courts should treat these petitions like other delayed claims, applying laches or changing Rule 9(a) to permit dismissal when delay makes reprosecution impossible. He proposed narrow exceptions for a believable claim of innocence, a clear miscarriage of justice, or when the claim could not have been found earlier with reasonable diligence.

Real world impact

If adopted, this approach would make it easier for states to have very old habeas petitions dismissed when lost witnesses or evidence would prevent a fair retrial. It aims to reduce repeated reopening of long-closed criminal cases and the burden on courts and victims. Because the Court simply denied review here, no new national rule was adopted in this opinion; the Chief Justice’s views urge change but are not binding law.

Dissents or concurrances

Justice Blackmun stated he would have granted review, signaling at least one Justice disagreed with leaving the lower-court handling of the petition undisturbed.