McCorquodale v. Texas

Background

A man named William McCorquodale was indicted in Brazos County, Texas, for the murder of Henry Spell. A jury found him guilty of first-degree murder on April 1, 1905, and he was later sentenced to life in the state penitentiary. The Texas Court of Criminal Appeals affirmed his conviction and sentence. The State then asked that the formal written judgment be corrected to include specific language required by Texas law. The state court granted that request and entered a reformed judgment. McCorquodale objected and asked for a rehearing, arguing the correction deprived him of due process and that the court lacked power to enter the original formal judgment.

Reasoning

The main question was whether the United States Supreme Court could review a federal due-process argument that was raised for the first time in a late petition for rehearing in the state court. The Supreme Court explained a long-standing rule: a federal claim cannot be first presented in a state court’s rehearing petition and then be reviewed here unless the state court actually considered and ruled on that federal question. Because the Texas court’s action was simply a denial of the rehearing request and did not plainly decide the federal due-process issue, the Supreme Court would not consider it.

Real world impact

The Supreme Court dismissed the appeal. That leaves the Texas conviction and the state court’s corrected judgment in place for now. The decision emphasizes that defendants must raise federal constitutional claims in a timely manner in state court if they want those issues reviewed later by the U.S. Supreme Court.