Wade v. Mayo - 334 U.S. 672 (1948)
U.S. Supreme Court
Wade v. Mayo, 334 U.S. 672 (1948)
Wade v. Mayo
Submitted October 13, 1947
Resubmitted March 9, 1948
Decided June 14, 1948
334 U.S. 672
1. Imprisoned under a Florida state court conviction of a noncapital offense, petitioner sought release by habeas corpus in a state court, claiming denial of his federal constitutional right to counsel. An appeal from a judgment denying relief was dismissed by the state supreme court on the merits. At the time of the state supreme court's action, its judgment apparently could have rested on an adequate nonfederal ground, but, in a later case, the court made clear that it had decided the federal constitutional question.
Held: although petitioner did not seek certiorari from this Court to review the judgment of the state supreme court, it was within the discretion of the federal district court to entertain an application by petitioner for a writ of habeas corpus and to proceed to a determination of petitioner's federal constitutional claim. Pp. 334 U. S. 674-682.
(a) The failure of petitioner to appeal from the judgment of conviction does not bar relief, since it appears that a defendant who is denied counsel in a noncapital case in Florida may raise the constitutional question either by appeal from the conviction or by habeas corpus, and pursuit of one of the two alternative remedies satisfies the requirement of exhaustion of state remedies. Pp. 334 U. S. 677-678.
(b) This Court accepts the pronouncement by the state supreme court in a later case that its decision in petitioner's habeas corpus
proceeding rested on the merits of the constitutional question, and not on a ruling that a direct appeal was the only way to raise the issue. Pp. 334 U. S. 678-679.
(c) The reasons for the rule requiring exhaustion of the state remedy cease when the highest state court has rendered a decision on the merits of the federal constitutional claim; the problem then is the nature and extent of the federal review of the constitutional issue. Pp. 334 U. S. 679-680.
(d) The fact that a state prisoner did not seek review by this Court of a judgment of the highest state court denying his claim of federal right may be a relevant consideration for the district court in determining whether to entertain a subsequent habeas corpus petition, but it does not absolutely bar exercise of the district court's discretion to entertain such a petition. P. 334 U. S. 680.
(e) Where it is apparent or even possible that a state prisoner's petition to this Court for certiorari to review a ruling by the highest state court on his claim of federal right would be denied because the judgment appears to be based on an adequate nonfederal ground, failure to file the petition should not prejudice the right to file a habeas corpus application in a federal district court. Pp. 334 U. S. 680-681.
(f) The flexible nature of the writ of habeas corpus counsels against erecting a rigid procedural rule that has the effect of imposing a new jurisdictional limitation on the writ. P. 334 U. S. 681.
(g) Where the matter is otherwise within the jurisdiction of the district court, it is within the discretion of that court to weigh the failure to seek certiorari against the miscarriage of justice that might result from a failure to grant relief. P. 334 U. S. 681.
(h) The fear that the exercise of the district court's power to entertain habeas corpus petitions in such circumstances as these might give rise to frequent instances of a single federal judge upsetting the judgment of a state court, often the highest court of the state, is without foundation. Pp. 334 U. S. 681-682.
2. At the commencement of his trial in a Florida state court for the noncapital offense of breaking and entering, petitioner, claiming to be without funds, requested the trial judge to appoint counsel to represent him. The request was refused, the trial proceeded, and petitioner was convicted and sentenced to imprisonment for five years. Petitioner, after exhausting his state remedy, applied to the federal district court for habeas corpus, claiming denial of his federal constitutional right to counsel. The district court found that, at the time of the trial in the state court, petitioner was an
inexperienced youth unfamiliar with court procedure and not capable of adequately representing himself. The district court concluded that the refusal of petitioner's request that counsel be appointed for him constituted a denial of due process, contrary to the Fourteenth Amendment of the Federal Constitution.
Held: the findings and conclusion of the district court were not clearly erroneous, and it was error for the Circuit Court of Appeals to reverse the district court's judgment. Pp. 334 U. S. 682-684.
(a) Refusal to appoint counsel for a defendant in a criminal case who, by reason of age, ignorance or mental capacity, is incapable of adequately representing himself, though the prosecution be of a relatively simple nature, is a denial of due process of law under the Fourteenth Amendment. P. 334 U. S. 684.
(b) Whether the failure to appoint counsel in a noncapital case in a state court constitutes a denial of due process under the Fourteenth Amendment does not depend upon whether the law of the state requires such an appointment. P. 334 U. S. 684.
158 F.2d 614 reversed.
In a habeas corpus proceeding in which petitioner sought release from imprisonment under a state court judgment of conviction, the federal district court granted relief on the ground that a federal constitutional right had been denied petitioner at his trial in the state court. The Circuit Court of Appeals reversed. 158 F.2d 614. This Court granted certiorari. 331 U.S. 801. Reversed, p. 334 U. S. 684.