Deborah K. Johnson, Warden v. Donna Kay Lee (578 U.S. 605)
U.S. Supreme Court · decided May 31, 2016 · Supreme Court Database (Spaeth)
- Citation
- 578 U.S. 605 · 136 S. Ct. 1802
- Decided
- May 31, 2016
- Term
- October Term 2015
- Vote
- 8–0
- Issue area
- Criminal Procedure
- Disposition
- Reversed
- Outcome
- Petitioning party lost
- Ideological direction
- Conservative
Opinion excerpt
PER CURIAM. Federal habeas courts generally refuse to hear claims "defaulted ... in state court pursuant to an independent and adequate state procedural rule." Coleman v. Thompson, 501 U.S. 722, 750, 111 S.Ct. 2546, 115 L.Ed.2d 640 (1991). State rules count as "adequate" if they are "firmly established and regularly followed." Walker v. Martin, 562 U.S. 307, 316, 131 S.Ct. 1120, 179 L.Ed.2d 62 (2011) (internal quotation marks omitted). Like all States, California requires criminal defendants to raise available claims on direct appeal. Under the so-called "Dixon bar," a defendant procedurally defaults a claim raised for the first time on state collateral review if he could have raised it earlier on direct appeal. See In re Dixon, 41 Cal.2d 756, 759, 264 P.2d 513, 514 (1953). Yet, in this case, the Ninth Circuit held that the Dixon bar is inadequate to bar federal habeas review. Because California's procedural bar is longstanding, oft-cited, and shared by habeas courts across the Nation, this Court now summarily reverses the Ninth Circuit's judgment. I Respondent Donna Kay Lee and her boyfriend Paul Carasi stabbed to death Carasi's mother and his ex-girlfriend. A California jury convicted the pair of two counts each of first-degree murder. Carasi received a death sentence, and Lee received a sentence of life without the possibility of parole. In June 1999, Lee unsuccessfully…
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