Mintzes v. Buchanon

1985-04-15

Headline: After a man convicted of two murders died, the Court vacated its grant of review and dismissed the petition, ending Supreme Court consideration and leaving the appeals court ruling in place.

Holding: Upon learning that the man convicted of two murders while a fugitive had died, the Court vacated its grant of review and dismissed the petition, ending Supreme Court consideration of the case.

Real World Impact:

Leaves the appeals court ruling in place, potentially binding between the parties.
Creates uncertainty about the opinion’s precedential weight in the Sixth Circuit.
Ends Supreme Court review without resolving the underlying counsel or guilt claims.

Topics: habeas corpus, case mooted by death, dismissal of review, lower-court precedent uncertainty

Summary

Background

The State of Michigan asked the Supreme Court to review a decision that had ordered a man either released or given a new hearing and resentencing for two murders he committed while a fugitive from prison. The respondent later died in Ingham County, Michigan, on December 7, 1984, after the Court had already granted review.

Reasoning

The central question was what the Court should do when a case becomes moot because the person at the center of the case has died. The Court issued a short, unanimous per curiam order: it vacated its earlier grant of review and dismissed the petition for certiorari, citing the Court’s prior practice in Warden v. Palermo. That action ended Supreme Court consideration and left the Court of Appeals’ judgment standing. Justice Powell did not take part in the decision.

Real world impact

Because the Supreme Court dismissed review rather than vacating the appeals court judgment, the lower court opinion remains and could be cited in later proceedings. The ruling is a procedural outcome, not a decision on the underlying claims about counsel or guilt, and it therefore does not settle those merits questions.

Dissents or concurrances

Chief Justice Burger dissented, arguing the Court should have vacated the Court of Appeals’ judgment and directed dismissal as moot so the lower opinion would not stand as precedent; he relied on earlier cases and urged the Court to avoid leaving the status of the appeals opinion uncertain.