William Duncan, Warden v. Robert E. Henry (513 U.S. 364)
U.S. Supreme Court · decided January 23, 1995 · Supreme Court Database (Spaeth)
- Citation
- 513 U.S. 364 · 115 S. Ct. 887
- Decided
- January 23, 1995
- Term
- October Term 1994
- Vote
- 8–1
- Issue area
- Criminal Procedure
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Per Curiam. Respondent, a rector and dean of a church day school, was tried and convicted in state court of sexually molesting a 5-year-old student. At trial, respondent objected to testimony by the parent of another child who claimed to have been molested 20 years previously. His objection was based on Cal. Evid. Code Ann. §352 (West 1966). On direct appeal, he pursued his evidentiary objection and requested the appellate court to find that the error was a “miscarriage of justice” under the California Constitution. California applies this provision in determining whether or not an error was harmless. People v. Watson, 46 Cal. 2d 818, 299 P. 2d 243 (1956). The California Court of Appeal found the error harmless and affirmed respondent’s conviction. People v. Henry, No. CR23041 (2d Dist. 1990), App. D to Pet. for Cert. 6. Respondent then filed a petition for writ of habeas corpus in federal court, alleging that the evidentiary error amounted to a denial of due process under the United States Constitution. The District Court granted the petition and the Court of Appeals for the Ninth Circuit affirmed. Henry v. Estelle, 33 F. 3d 1037 (1994). The court held that respondent had exhausted his state remedies even though he had not claimed a violation of any federal constitutional right in the state proceedings: “In his direct appeal in state court, Henry did not label his claim a…
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