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In re Davis (Writ of Habeas Corpus)

Supreme Court of the United States
557 U.S. 952, 174 L. Ed. 2d 614 (2009)
ELI5:

Rule of Law:

Under its original habeas corpus jurisdiction, the Supreme Court may transfer a state prisoner's petition to a district court for an evidentiary hearing when there are exceptional circumstances, such as a substantial, post-trial showing of actual innocence in a capital case, notwithstanding statutory limitations on federal habeas review.


Facts:

  • Troy Anthony Davis was present during the beating of a homeless man in a restaurant parking lot.
  • Off-duty police officer Mark Allen MacPhail, working as a security guard, responded to the altercation.
  • Officer MacPhail was shot multiple times and killed during the incident.
  • After Davis was convicted of the murder, seven of the nine key witnesses for the State recanted their trial testimony.
  • In post-conviction affidavits, several individuals implicated another man, who was the State's principal witness at trial, as the actual shooter.

Procedural Posture:

  • Troy Davis was convicted of murder in a Georgia state trial court and sentenced to death.
  • The Georgia Supreme Court, the state's highest court, affirmed his conviction and sentence on direct appeal.
  • Davis filed state habeas corpus petitions and an extraordinary motion for a new trial based on new evidence, including witness recantations; the Georgia Supreme Court ultimately denied this motion.
  • The Georgia Board of Pardons and Paroles denied Davis's request for clemency after conducting its own investigation.
  • Davis filed a petition for a writ of habeas corpus in federal district court, which was denied. The U.S. Court of Appeals for the Eleventh Circuit, an intermediate federal appellate court, affirmed the denial.
  • Davis then filed an original petition for a writ of habeas corpus directly with the Supreme Court of the United States.

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Issue:

Does a state prisoner's substantial post-conviction claim of actual innocence, supported by numerous witness recantations and new evidence, constitute an 'exceptional circumstance' warranting the transfer of an original writ of habeas corpus to a district court for an evidentiary hearing?


Opinions:

Concurring - Justice Stevens

This is the concurring opinion, joined by Justices Ginsburg and Breyer, which agrees with the Court's unsigned order to transfer the case to a lower court for a hearing. Yes, such a claim constitutes an exceptional circumstance warranting a hearing. The substantial risk of executing an innocent person justifies the Court exercising its original habeas jurisdiction. Justice Scalia's dissent wrongly assumes Davis's guilt when no court has ever held a hearing to assess the reliability of the new evidence. Furthermore, it is not a 'fool's errand,' because the district court has several potential avenues to grant relief; it might find that the strict limitations of the Antiterrorism and Effective Death Penalty Act (AEDPA) do not apply to original habeas petitions, that there is an 'actual innocence' exception to AEDPA, or that applying AEDPA to bar relief for a demonstrably innocent person would be unconstitutional.


Dissenting - Justice Scalia

This is the dissenting opinion, joined by Justice Thomas, which disagrees with the decision to transfer the case. No, this claim does not warrant a hearing because the lower court has no power to grant relief. Transferring the petition is a 'fool's errand' because federal law, specifically the Antiterrorism and Effective Death Penalty Act (AEDPA), bars federal courts from granting habeas relief unless a state court decision was contrary to 'clearly established Federal law.' This Court has never held that 'actual innocence' is a standalone constitutional claim, so the Georgia courts did not violate clearly established law by rejecting it. Davis's evidence is stale and has already been reviewed and rejected by multiple state and federal bodies. The Court's order serves no purpose but to delay the execution of a lawful judgment.



Analysis:

This case is significant for its rare exercise of the Supreme Court's original habeas jurisdiction, signaling the Court's willingness to intervene in a state capital case based on a powerful post-conviction claim of actual innocence. The decision highlights the profound tension between the finality of judgments, as enforced by AEDPA, and the fundamental principle of preventing the execution of an innocent person. By ordering a hearing, the Court sidestepped the unresolved constitutional question of whether executing a factually innocent individual is permissible, but it strongly implied that such claims demand judicial review despite significant procedural hurdles. The case underscores the ongoing legal and moral debate over actual innocence as a basis for post-conviction relief in the modern era of habeas restrictions.

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