Facts of the Case
Lloyd Powell was convicted of murder by a California court. Powell sought relief in federal district court by filing a writ of federal habeas corpus. Powell claimed that the search that uncovered the murder weapon was unlawful and that the evidence should have been inadmissible at trial. This case was decided together with Wolf v. Rice.
Questions
Were federal courts obligated to consider claims of illegal searches and seizures after such claims had been decided by state courts?
Conclusions
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In a 6-to-3 decision, the Court held that where states had provided opportunities for full and fair litigation of Fourth Amendment claims, the Constitution did not require the granting of federal habeas corpus relief. The Court also held that any additional benefits from considering search and seizure claims of state prisoners on collateral review would be small in relation to the costs. The Court found that the Fourth Amendment values protected by the exclusionary rule would not be significantly enhanced in such situations and that deterrence of police misconduct was unlikely to increase.
The ABA and Criminal Justice Issues
INTRODUCTION In 1996, the Federalist Society for Law and Public Policy Studies launched fifteen legal...
Major Habeas Reform Package Becomes Law
Criminal Law & Procedure Practice Group Newsletter - Volume 1, Issue 1, Fall 1996
New deference standard requires federal courts to respect state court legal and constitutional rulings; Act...
