Sumner v. Mata
449 U.S. 539 (1981)
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Rule of Law:
Under 28 U.S.C. § 2254(d), a federal court granting a writ of habeas corpus to a state prisoner must presume that the state court's factual findings are correct. If the federal court concludes otherwise, it must explicitly state in its opinion which of the statutory exceptions to this presumption justifies its decision.
Facts:
- An inmate was murdered inside a California correctional institution in 1973.
- Three fellow inmates witnessed all or part of the attack.
- State police conducted a pretrial photographic identification procedure with the three inmate witnesses.
- During this procedure, two of the witnesses were shown photo arrays on three separate occasions.
- All three witnesses identified Robert Mata as a participant in the murder.
- At trial, Mata offered an alibi defense, presenting three other witnesses who testified he was in bed at the time of the stabbing.
Procedural Posture:
- Robert Mata was convicted of first-degree murder in the Superior Court of Kern County, California, a state trial court.
- On direct appeal to the California Court of Appeal, an intermediate state appellate court, Mata argued for the first time that the pretrial photographic identification procedure was unconstitutional.
- The California Court of Appeal affirmed the conviction, rejecting Mata's due process claim.
- Mata did not seek direct review in the California Supreme Court but later filed state habeas corpus petitions in all three levels of the state court system, which were all denied.
- Mata then filed a petition for a writ of habeas corpus in the U.S. District Court for the Northern District of California, a federal trial court.
- The District Court denied Mata's habeas petition.
- Mata appealed to the U.S. Court of Appeals for the Ninth Circuit, a federal intermediate appellate court.
- The Ninth Circuit reversed the District Court's decision, holding that the identification procedure was unconstitutional and that Mata's conviction was invalid.
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Issue:
Does 28 U.S.C. § 2254(d) require a federal court, when granting a writ of habeas corpus, to explicitly state its reasoning for concluding that a state court's factual findings are not entitled to the statute's presumption of correctness?
Opinions:
Majority - Justice Rehnquist
Yes. A federal habeas court granting relief must explicitly explain its reasoning for disregarding a state court's factual findings under 28 U.S.C. § 2254(d). The statute establishes a 'presumption of correctness' for factual determinations made by state courts, and this presumption can only be overcome if one of the eight enumerated conditions in the statute is met. The purpose of this provision is to promote federalism, reduce friction between federal and state courts, and ensure finality. This presumption applies to factual findings made by state appellate courts just as it does to those made by state trial courts. To ensure Congress's intent is followed, a federal court that rejects a state court's findings must include in its opinion the reasoning that led it to conclude one of the statutory exceptions was present or that the state finding was 'not fairly supported by the record.' In this case, the Court of Appeals for the Ninth Circuit failed to mention § 2254(d) or provide any such reasoning, so its judgment must be vacated and the case remanded for proceedings consistent with this requirement.
Dissenting - Justice Brennan
No. A federal court is not required to explain its application of § 2254(d), particularly when the state failed to properly raise the argument on appeal and the statute is inapplicable to the issue at hand. The state abandoned its § 2254(d) argument before the Court of Appeals, and a court is not required to address arguments the parties themselves do not make. More fundamentally, § 2254(d) applies only to determinations of 'factual issue[s],' not to mixed questions of law and fact. The core dispute here—whether a pretrial identification procedure was 'so impermissibly suggestive' as to violate due process—is a mixed question requiring the application of constitutional principles to historical facts. The federal and state courts did not disagree on the basic facts but on their legal significance. Therefore, § 2254(d)'s presumption of correctness does not apply, and the Court of Appeals was free to conduct an independent review of the constitutional claim.
Analysis:
This decision significantly strengthens the doctrine of deference that federal courts must afford state court factual findings in habeas corpus proceedings. It clarifies that the presumption of correctness under 28 U.S.C. § 2254(d) applies to state appellate courts and imposes a clear procedural requirement on federal courts to justify any departure from that presumption in writing. This ruling reinforces principles of federalism and finality, making it more difficult for federal courts to second-guess state adjudications and for state prisoners to obtain habeas relief based on factual disputes. The holding effectively requires federal courts to show their work, thereby increasing transparency and limiting their power to overturn state convictions without explicit statutory justification.
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