SCOTUS eases process for death row appeals

In Hill v. McDonough, Clarence E. Hill challenged the constitutionality of a three-drug sequence the State of Florida likely would use to execute him by lethal injection. Seeking to enjoin the procedure, he filed in the United States District Court a Section 1983 suit. The District Court and the Court of Appeals for the Eleventh Circuit construed the action as a petition for a writ of habeas corpus and ordered it dismissed for noncompliance with the requirements for a second and successive petition. The Supreme Court held that this was error and that Hill should have been allowed to proceed under Section 1983.

In House v. Bell, the Court considered the procedural default rule in connection with a petition for habeas corpus. Twenty years ago, a jury convicted Paul Gregory House for murder and sentenced him to death. Since then, new revelations cast doubt on the jury's verdict. House sought access to federal court to pursue habeas corpus relief based on constitutional claims that were procedurally barred under state law. As a general rule, federal courts are closed to claims that state courts would consider defaulted. The Supreme Court held that the DNA evidence discovered was an exceptional circumstance involving a compelling claim of actual innocence and thus the state procedural default rule cannot bar a federal habeas corpus petition.

Here is a news story from the Boston Globe on the two opinions.

SCOTUS Blog has this post.