Allen v. McCurry, 449 U.S. 90 (1980)
While 42 U.S.C. 1983 is designed to provide a remedy for civil harm, the distinct remedy of habeas corpus should be used by a federal court to release an individual from unlawful physical confinement.
McCurry sought to suppress evidence that had been seized by police from being used at trial, based on the Fourth and Fourteenth Amendments. His motion was denied, and he was eventually convicted. McCurry was unsuccessful in appealing his conviction and also was barred from going to federal court for a writ of habeas corpus on the grounds that he had failed to claim that he had not received a full and fair opportunity to litigate the alleged search and seizure violation in state courts. McCurry pursued a damages claim based on the same subject matter in federal court under 42 U.S.C. Section 1983, suing Allen and other police officers who had seized the evidence.Opinions
- Potter Stewart (Author)
- Warren Earl Burger
- Byron Raymond White
- Lewis Franklin Powell, Jr.
- William Hubbs Rehnquist
- John Paul Stevens
Disregarding the collateral estoppel doctrine, the appellate court had directed the trial court to allow the defendant's claim to proceed because it perceived this type of action as the only way for him to litigate this issue in a federal court. Section 1983 does not support the appellate court's decision because it contains no statement of congressional intent to withhold finality from a state court judgment or decision if the parties had a full and fair opportunity to litigate federal claims in that forum, and its jurisdiction was proper. State courts are capable of protecting federal rights, and the doctrine of collateral estoppel does not permit a party suing to enforce a federal right to restart the litigation in federal court once the state court has reached a valid decision on it. Just because the defendant did not choose to engage in the criminal litigation in federal court does not mean that he can avoid the application of collateral estoppel.
- Harry Andrew Blackmun (Author)
- William Joseph Brennan, Jr.
- Thurgood Marshall
It is implausible to interpret a Fourth Amendment claim raised by a criminal defendant in state court as proof that the defendant freely and without reservation submitted all federal claims for decision by state courts. Criminal defendants do not voluntarily participate in these proceedings, and they are at a stark disadvantage against the resources of the state. They should not be required to choose between raising a certain defense and waiving a future civil claim arising from the same alleged constitutional violation.Case Commentary
The Court raised as many questions as it answered with this decision, such as whether claims that could have been raised but were not raised in the state court would be precluded.
U.S. Supreme CourtAllen v. McCurry, 449 U.S. 90 (1980)
Allen v. McCurry
Argued October 8, 1980
Decided December 9, 1980
449 U.S. 90
At a hearing before respondent's criminal trial, a Missouri court denied, in part, respondent's motion to suppress, on Fourth and Fourteenth Amendment grounds, certain evidence that had been seized by the police. Respondent was subsequently convicted, and the conviction was affirmed on appeal. Because he did not assert that the state courts had denied him a "full and fair opportunity" to litigate his search and seizure claim, respondent was barred by Stone v. Powell, 428 U. S. 465, from seeking a writ of habeas corpus in a federal district court. Nevertheless, he sought federal court redress for the alleged constitutional violation by bringing a suit for damages under 42 U.S.C. § 1983 against the officers who had seized the evidence in question. The Federal District Court granted summary judgment for the defendants, holding that collateral estoppel prevented respondent from relitigating the search and seizure question already decided against him in the state courts. The Court of Appeals reversed and remanded, noting that Stone v. Powell, supra, barred respondent from federal habeas corpus relief, and that the § 1983 suit was, therefore, respondent's only route to a federal forum for his constitutional claim, and directed the trial court to allow him to proceed to trial unencumbered by collateral estoppel.
Held: The Court of Appeals erred in holding that respondent's inability to obtain federal habeas corpus relief upon his Fourth Amendment claim renders the doctrine of collateral estoppel inapplicable to his § 1983 suit. Nothing in the language or legislative history of § 1983 discloses any congressional intent to deny binding effect to a state court judgment or decision when the state court, acting within its proper jurisdiction, has given the parties a full and fair opportunity to litigate federal claims, and thereby has shown itself willing and able to protect federal rights. Nor does anything in § 1983's legislative history reveal any purpose to afford less deference to judgments in state criminal proceedings than to those in state civil proceedings. Pp. 449 U. S. 94-105.
606 F.2d 795, reversed and remanded.
STEWART, J., delivered the opinion of the Court, in which BURGER, C.J., and WHITE, POWELL, REHNQUIST, and STEVENS, JJ., joined. BLACKMUN,
J., filed a dissenting opinion, in which BRENNAN and MARSHALL, JJ., joined, post p. 449 U. S. 105.