Stone v. Powell
428 U.S. 465 (1976)
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Rule of Law:
Where a state has provided an opportunity for full and fair litigation of a Fourth Amendment claim, a state prisoner may not be granted federal habeas corpus relief on the ground that evidence obtained in an unconstitutional search or seizure was introduced at trial.
Facts:
- In the first case, Lloyd Powell and three companions entered a liquor store in San Bernardino, California, where Powell became involved in an altercation with the store manager.
- During the scuffle, Powell shot and killed the manager's wife.
- Ten hours later, a police officer in Henderson, Nevada, arrested Powell for violating a local vagrancy ordinance.
- In a search incident to that arrest, the officer discovered the .38-caliber revolver that was used in the murder.
- In the second case, an Omaha police officer was killed by an exploding suitcase bomb.
- The investigation focused on members of the National Committee to Combat Fascism (NCCF), including David Rice.
- Police obtained a warrant to search Rice's home for explosives and, upon entering, discovered dynamite, blasting caps, and other bomb-making materials.
- After Rice later surrendered, a chemical analysis of his clothing revealed dynamite particles.
Procedural Posture:
- In separate state court trials, Lloyd Powell was convicted of murder in California, and David Rice was convicted of murder in Nebraska.
- At their respective trials, both Powell and Rice moved to suppress evidence, arguing it was obtained through unconstitutional searches and seizures; both trial courts denied the motions.
- Both convictions were affirmed on direct appeal by the highest available state appellate courts.
- Powell and Rice then each filed petitions for a writ of habeas corpus in their respective United States District Courts.
- The U.S. District Court denied Powell's petition, but the U.S. Court of Appeals for the Ninth Circuit reversed, ordering that the writ be granted.
- The U.S. District Court granted Rice's petition, and the U.S. Court of Appeals for the Eighth Circuit affirmed.
- The prison wardens in both cases, Stone and Wolff, petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does federal habeas corpus relief for a state prisoner extend to a claim that unconstitutionally seized evidence was introduced at trial, when the prisoner has already had an opportunity for full and fair litigation of the Fourth Amendment claim in state courts?
Opinions:
Majority - Justice Powell
No. Federal habeas corpus relief does not extend to a state prisoner's Fourth Amendment claim where the state has already provided an opportunity for full and fair litigation of that claim. The primary purpose of the Fourth Amendment's exclusionary rule is to deter unlawful police conduct, not to vindicate a personal constitutional right of the aggrieved party. Applying the rule on collateral habeas review provides only a minimal incremental deterrent benefit, which is heavily outweighed by the societal costs, such as diverting the trial's focus from guilt or innocence, excluding reliable evidence, and undermining the finality of state court convictions. The Court reasoned that state courts are fully competent and constitutionally obligated to adjudicate Fourth Amendment claims, and that federal habeas review is not necessary to encourage them to do so.
Concurring - Chief Justice Burger
Yes, I concur with the Court's opinion, but the exclusionary rule itself is a flawed, judicially created device that has failed to demonstrate any significant deterrent effect. Its function is to exclude truth from the fact-finding process, and its continued existence in its current, absolutist form inhibits the development of more rational and effective alternatives to deter police misconduct, such as statutory remedies. The time has come to modify the rule's reach, limiting it to cases involving egregious, bad-faith conduct by police.
Dissenting - Justice Brennan
Yes. The Court's decision is not a constitutional holding but rather an improper judicial reinterpretation of the federal habeas corpus statutes, usurping a power that belongs to Congress. A person convicted based on unconstitutionally seized evidence is 'in custody in violation of the Constitution' under the plain language of 28 U.S.C. § 2254, and that constitutional deprivation does not vanish simply because the claim is raised on collateral review instead of direct appeal. This ruling effectively creates a hierarchy of constitutional rights, relegating the Fourth Amendment to a 'second-class' status, and portends a drastic withdrawal of federal habeas jurisdiction for other constitutional claims deemed not 'guilt-related'.
Dissenting - Justice White
Yes. For the reasons stated by Justice Brennan, the habeas corpus statute does not distinguish between Fourth Amendment claims and other constitutional issues, and barring such claims on habeas can lead to unjust results where two identical cases are treated differently. However, the exclusionary rule itself should be substantially modified to include a good-faith exception. The rule should not apply when evidence is seized by an officer acting with a reasonable, good-faith belief that their conduct was lawful, as excluding such evidence serves no deterrent purpose and is a senseless obstacle to the truth-finding process.
Analysis:
Stone v. Powell significantly restricts the scope of federal habeas corpus review for state prisoners, effectively closing the federal courts to most Fourth Amendment exclusionary rule claims. By prioritizing principles of finality and federalism, the decision shifts the ultimate authority for adjudicating these specific federal claims to the state courts. This ruling established the 'opportunity for a full and fair litigation' standard as a threshold barrier, preventing federal re-litigation of the merits of a search-and-seizure issue. The decision also reflects the Court's growing skepticism toward the exclusionary rule's cost-benefit calculus, laying the groundwork for future modifications and exceptions to the rule.
