Cardinale v. Louisiana
1969 U.S. LEXIS 2049, 394 US 437, 22 L. Ed. 2d 398 (1969)
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Rule of Law:
The U.S. Supreme Court will not exercise its appellate jurisdiction to decide a federal constitutional question on review of a state court judgment unless that question was raised, preserved, and decided in the state court proceedings.
Facts:
- Stanley Cardinale murdered a woman near New Orleans and fled the state.
- An arrest warrant was issued for Cardinale.
- While in Tucson, Arizona, Cardinale decided to surrender and flagged down a police car.
- After being warned of his right to remain silent and his right to an attorney, Cardinale was taken to the police station.
- At the station, Cardinale voluntarily gave a full confession to the murder.
Procedural Posture:
- Stanley Cardinale was tried for murder in a Louisiana state trial court.
- Pursuant to Louisiana statute § 15:450, Cardinale's entire confession was admitted into evidence.
- The trial court convicted Cardinale and sentenced him to death.
- Cardinale appealed his conviction through the Louisiana state court system, but at no point did he argue that the state statute regarding confessions violated the U.S. Constitution.
- Cardinale petitioned the U.S. Supreme Court for a writ of certiorari to challenge the constitutionality of the Louisiana statute, and the Court granted the writ.
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Issue:
Does the U.S. Supreme Court have jurisdiction to review a federal constitutional challenge to a state statute when the petitioner failed to raise that constitutional issue in the state courts below?
Opinions:
Majority - Mr. Justice White
No. The Supreme Court lacks jurisdiction to review a federal constitutional question that was not raised, preserved, or passed upon in the state courts. This principle, established since the Judiciary Act of 1789, is rooted in both statutory jurisdictional limits and sound judicial policy. The Court's precedent consistently holds that for its appellate jurisdiction to attach, a federal question must have been presented to and decided by the state court. This rule ensures that the factual record is adequately developed for the federal question and, under principles of federalism, gives state courts the first opportunity to construe their own statutes in light of constitutional challenges, potentially avoiding the federal issue altogether.
Concurring - Mr. Justice Black, Mr. Justice Douglas, and Mr. Justice Fortas
These justices concurred in the dismissal of the writ, stating their belief that it had been improvidently granted, rather than dismissed for a lack of jurisdiction.
Analysis:
This case solidifies a fundamental procedural requirement for Supreme Court review of state court decisions. It underscores the principle of federalism by requiring that state courts be given the first opportunity to address federal constitutional challenges to their own laws. The decision reinforces the 'raise or waive' rule, meaning litigants who fail to present federal claims in state court forfeit the right to have the Supreme Court consider them on direct review. This creates a significant procedural hurdle for petitioners and emphasizes the importance of thorough litigation at the state level before seeking federal intervention.
