Engle v. Isaac
456 U.S. 107 (1982)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A state prisoner who fails to comply with a state's contemporaneous objection rule at trial is barred from litigating that constitutional claim in a federal habeas corpus proceeding unless they can demonstrate both cause for the procedural default and actual prejudice resulting from the alleged constitutional violation.
Facts:
- In December 1974, respondent Hughes shot and killed a man who was with Hughes's former girlfriend; Hughes claimed he acted in self-defense.
- In April 1975, respondent Bell pursued and shot a man to death after being called to another bar to assist with potential trouble; Bell claimed he acted in self-defense.
- In September 1975, respondent Isaac severely beat his former wife's boyfriend; Isaac claimed he acted in self-defense.
- At the time of these incidents, a new Ohio statute, § 2901.05(A), had taken effect on January 1, 1974, which addressed the burden of proof for affirmative defenses.
- For over a century before, and for over two years after the new statute's enactment, Ohio courts consistently required criminal defendants to prove the affirmative defense of self-defense by a preponderance of the evidence.
Procedural Posture:
- Respondents Hughes, Bell, and Isaac were separately convicted in Ohio state trial courts of various homicide and assault charges.
- In each trial, the judge instructed the jury that the defendant had the burden of proving self-defense by a preponderance of the evidence; defense counsel did not object to this instruction.
- After their convictions, the Ohio Supreme Court held in State v. Robinson that the prosecution must disprove self-defense beyond a reasonable doubt once the issue is raised.
- The respondents' direct appeals in the Ohio court system were unsuccessful; Isaac's claim was specifically rejected by a state appellate court because of his failure to object at trial.
- All three respondents filed separate petitions for a writ of habeas corpus in federal district courts, which were all denied.
- On appeal, the U.S. Court of Appeals for the Sixth Circuit reversed all three district court decisions, finding cause and prejudice to excuse the procedural default.
- The U.S. Supreme Court granted certiorari to review the Sixth Circuit's judgments.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a state prisoner's failure to comply with a state's contemporaneous objection rule at trial bar federal habeas corpus review of a constitutional claim, absent a showing of cause for the failure to object and actual prejudice resulting from the alleged constitutional violation?
Opinions:
Majority - Justice O’Connor
Yes. A state prisoner who has procedurally defaulted on a constitutional claim in state court may not obtain federal habeas relief without showing cause for the default and actual prejudice from the alleged constitutional violation. The principles of Wainwright v. Sykes apply to all constitutional claims, including those that affect the truthfinding function of the trial. The perception that an objection would have been futile in state court does not constitute 'cause' for a procedural default, as defendants cannot bypass state courts simply because they believe them to be unsympathetic. Furthermore, 'cause' is not established by the novelty of a constitutional claim if the legal basis for that claim was available and other attorneys had perceived and litigated it. In this case, the constitutional claim's foundation was laid in In re Winship (1970), years before the respondents' trials, meaning the 'tools to construct their constitutional claim' were available. The significant costs of federal habeas review—including the erosion of finality, infringement on state sovereignty, and diminishment of the trial's significance—justify enforcing state procedural rules through the strict cause-and-prejudice standard.
Dissenting - Justice Brennan
No. The Court misconstrues respondent Isaac's claim, which was not about the jury instruction itself, but about Ohio's selective retroactive application of a new state supreme court ruling. This claim could not have been raised at trial, so there was no procedural default to which the Sykes standard could apply; Isaac's petition should have been dismissed for failure to exhaust state remedies under Rose v. Lundy. Furthermore, the 'cause' standard articulated by the majority is unreasonably harsh, essentially requiring clairvoyance from defense counsel. The Sykes cause-and-prejudice standard should not be applied to errors that, like an unconstitutional shift in the burden of proof, fundamentally impair the truth-finding function of the trial and create a high risk of convicting the innocent. Such cases represent a 'miscarriage of justice' that federal habeas corpus is designed to correct.
Concurring-in-part-and-dissenting-in-part - Justice Stevens
The Court should not engage in a complex analysis of procedural hurdles. Instead, it should deny the petitions by ruling on the merits of the respondents' underlying constitutional claims. Neither of the exhausted claims presented is plausible; the Constitution does not require the prosecution to prove the absence of self-defense beyond a reasonable doubt in this context. Because the substantive constitutional claims fail on their merits, the procedural question of whether there was cause and prejudice for the trial default is irrelevant. The Court's preoccupation with procedural rules complicates rather than simplifies the processing of habeas petitions.
Analysis:
This decision significantly strengthens and expands the procedural default doctrine from Wainwright v. Sykes, making it more difficult for state prisoners to obtain federal habeas review. By narrowly defining 'cause' to exclude perceived futility and the novelty of a claim, the Court raised the bar for excusing a failure to object at trial. This prioritizes the principles of finality and comity with state courts over the federal adjudication of defaulted constitutional claims. The ruling forces defense counsel to be vigilant in raising all potential constitutional arguments during trial, regardless of existing precedent, thereby reducing the scope of federal collateral review and reinforcing the primacy of the state trial proceeding.
Unlock the full brief for Engle v. Isaac