Shoop v. Twyford

Background

A death-row prisoner in Ohio sought to be taken from prison to a hospital for brain testing, saying a childhood head injury might explain his behavior and help his challenges to the conviction. The federal district court ordered the State to transport him for testing under a general power called the All Writs Act. A federal appeals court agreed, and the State asked the Supreme Court to review whether that transportation order was proper.

Reasoning

The Court considered whether a federal judge may force a State to move a prisoner so the prisoner can search for new evidence. It emphasized that federal review of state convictions is tightly limited by a law called AEDPA, which generally restricts federal courts to the evidence that state courts saw. The Court said a transportation order that lets a prisoner “fish” for evidence that would later be inadmissible would needlessly prolong cases and undermine finality and public safety. Because the prisoner had not shown that test results would be usable in his federal challenge, the Court concluded the order was not “necessary or appropriate” and reversed the appeals court.

Real world impact

Federal judges will generally require a concrete showing that proposed medical testing would produce admissible evidence before ordering a State to transport a prisoner. This makes it harder for inmates—especially those on death row—to obtain out-of-prison medical testing simply to look for evidence. The ruling also emphasizes states’ interest in finality and the safety risks of prisoner transport.

Dissents or concurrances

Three Justices dissented mainly on jurisdictional grounds, arguing the appeals court lacked authority to hear the case on an interlocutory basis, and one Justice would have dismissed the case as improvidently granted.