Townsend v. Sain - 372 U.S. 293 (1963)
U.S. Supreme Court
Townsend v. Sain, 372 U.S. 293 (1963)
Townsend v. Sain
Argued February 19, 1962
Restored to the calendar for reargument April 2, 1962
Reargued October 8-9, 1962
Decided March 18, 1963
372 U.S. 293
In a jury trial in a State Court, petitioner was convicted of murder and sentenced to death. After exhausting all state remedies, he petitioned a Federal District Court for a writ of habeas corpus, claiming that his conviction violated the Fourteenth Amendment because of the admission in evidence of a confession obtained while he was under the influence of drugs, including a "truth serum," administered by a police physician. Although the evidence was conflicting, the State Court had filed no opinion, conclusions of law or findings of fact. Respondents conceded in the District Court that a dispute existed as to whether the drug administered to petitioner was a "truth serum," as to its effects, and as to whether facts bearing on these questions had been concealed during the state court hearing on the admissibility of the confession. Nevertheless, the District Court denied petitioner an opportunity to call witnesses or to produce other evidence in support of his allegations. It dismissed his petition on the ground that it was satisfied from the state court records that the decision of the State Court, holding that the confession had been given freely and voluntarily, was correct, and that there had been no denial of federal due process of law. The Court of Appeals affirmed.
Held: On the record in this case, the District Court erred in denying a writ of habeas corpus without a plenary evidentiary hearing. Pp. 372 U. S. 295-322.
1. The petition for habeas corpus alleged a deprivation of constitutional rights, because petitioner's confession was constitutionally inadmissible if it was adduced by police questioning during a period when petitioner's will was overborne by a drug having the properties of a "truth serum." Pp. 372 U. S. 307-309.
2. When an application by a state prisoner to a Federal Court for a writ of habeas corpus alleges facts which, if proved, would entitle him to relief, the Federal Court to which the application is made has the power to receive evidence and try the facts anew. Pp. 372 U. S. 310-312.
3. Where the facts are in dispute, the Federal District Court must grant an evidentiary hearing if (1) the merits of the factual
dispute were not resolved in the state hearing, either at the time of the trial or in a collateral proceeding; (2) the state factual determination is not fairly supported by the record as a whole; (3) the factfinding procedure employed by the State Court was not adequate to afford a full and fair hearing; (4) there is a substantial allegation of newly discovered evidence; (5) the material facts were not adequately developed at the state court hearing; or (6) for any reason it appears that the state trier of fact did not afford the applicant a full and fair fact hearing. Pp. 372 U. S. 312-318.
(a) When the state trier of fact has made no express findings, the District Court must hold an evidentiary hearing if the State Court did not decide the issues of fact tendered to it, if the State Court applied an incorrect standard of constitutional law, or if, for any other reason, the District Court is unable to reconstruct the relevant findings of the state trier of fact. Pp. 372 U. S. 313-316.
(b) The Federal District Court must carefully scrutinize the state court record in order to determine whether the factual determinations of the State Court are fairly supported by the record. P. 372 U. S. 316.
(c) Even if all the relevant facts were presented in the state court hearing, it is the Federal Judge's duty to disregard the state findings and take evidence anew if the procedure employed by the State Court appears to be seriously inadequate for the ascertainment of the truth. P. 372 U. S. 316.
(d) Where newly discovered evidence which could not reasonably have been presented to the State Court is alleged, the Federal Court must grant an evidentiary hearing, unless the allegation of newly discovered evidence is irrelevant, frivolous or incredible. P. 372 U. S. 317.
(e) If, for any reason not attributable to the inexcusable neglect of the applicant, evidence crucial to the adequate consideration of his constitutional claim was not developed at the state hearing, the Federal Court must grant an evidentiary hearing. P. 372 U. S. 317.
(f) The duty to try the facts anew exists in every case in which the State Court has not, after a full hearing, reliably found the relevant facts. Pp. 372 U. S. 317-318.
4. In all other cases where the material facts are in dispute, the holding of an evidentiary hearing is in the discretion of the Federal District Judge. P. 372 U. S. 318.
5. Where the State Court has reliably found the relevant facts, the Federal District Judge may defer to the State Court's findings of fact, but he may not defer to the State Court's findings of law. P. 372 U. S. 318.
6. A District Court sitting in habeas corpus has power to compel production of the complete state court record or to hold an evidentiary hearing forthwith without compelling its production. Pp. 372 U. S. 318-319.
7. It rests largely with the Federal District Judges to give practical form to the above principles and to make proper accommodation between the competing factors involved. P. 372 U. S. 319.
8. In this case, the Court of Appeals erred in holding that, on habeas corpus, "the district court's inquiry is limited to a study of the undisputed portions of the record." Pp. 372 U. S. 319-320.
9. In the circumstances of this case, the District Judge should have held an evidentiary hearing, because he could not reconstruct the relevant findings of the state trier of fact and because the characterization of the drug administered as a "truth serum" was not brought out at the state court hearing. Pp. 372 U. S. 320-322.
10. The state court record is competent evidence at the District Court hearing, and either the petitioner or the State may rely solely upon the evidence contained in that record. P. 372 U. S. 322.
276 F.2d 324, reversed.