Thomas v. Arn
Annotate this Case
474 U.S. 140 (1985)
U.S. Supreme Court
Thomas v. Arn, 474 U.S. 140 (1985)
Thomas v. Arn
Argued October 7, 1985
Decided December 4, 1985
474 U.S. 140
Petitioner was convicted of homicide in an Ohio court, and ultimately the Ohio Supreme Court upheld the conviction. She sought habeas corpus relief in the Federal District Court, which referred the case to a Magistrate, who issued a report recommending denial of the writ and containing proposed findings and conclusions of law and a notice that failure to file objections within 10 days waived the right to appeal the District Court's order. Petitioner failed to file objections even though she had received an extension of time to do so, but the District Judge sua sponte reviewed the entire record de novo and dismissed the petition on the merits. On appeal, petitioner provided no explanation for her failure to object to the Magistrate's report. Without reaching the merits, the Court of Appeals affirmed, holding that petitioner had waived the right to appeal by failing to file objections to the Magistrate's report.
Held: A court of appeals may adopt a rule conditioning appeal, when taken from a district court judgment that adopts a magistrate's recommendation, upon the filing of objections with the district court identifying those issues on which further review is desired. Such a rule, at least when (as here) it incorporates clear notice to the litigants and an opportunity to seek an extension of time for filing objections, is a valid exercise of the court's supervisory power that does not violate either the Federal Magistrates Act or the Constitution. Pp. 474 U. S. 145-155.
(a) Here, the Court of Appeals intended to adopt a rule of procedure in the exercise of its supervisory power. Neither the intent nor the practical effect of the court's waiver rule is to restrict the court's own jurisdiction. Pp. 474 U. S. 145-146.
(b) The courts of appeals have supervisory powers that permit, at the least, the promulgation of procedural rules governing the management of litigation. The fact that the Sixth Circuit has deemed petitioner to have forfeited her statutory right to an appeal is not enough, standing alone, to invalidate the court's exercise of its supervisory power. Moreover, the Sixth Circuit's decision to require the filing of objections is supported by sound considerations of judicial economy. Pp. 474 U. S. 146-148.
(c) Neither the language nor the legislative history of the Federal Magistrates Act -- which provides that a litigant "may" file objections to
the magistrate's report within 10 days and thus obtain de novo review by the district judge, 28 U.S.C. § 636(b)(1)(C) -- supports petitioner's argument that the Act precludes the waiver rule adopted by the Sixth Circuit. The Act does not require that the district court review the magistrate's report under some lesser standard than de novo review when no objection is filed. Nor does the obligatory filing of objections under the Act extend only to findings of fact, and not to the magistrate's conclusions of law. Moreover, the waiver of appellate review is not inconsistent with the Act's purposes. Pp. 474 U. S. 148-153.
(d) The waiver of appellate review does not violate Article III of the Constitution. Although a magistrate is not an Article III judge, a district court may refer dispositive motions to a magistrate for a recommendation so long as the entire process takes place under the district court's control and jurisdiction, and the judge exercises the ultimate authority to issue an appropriate order. The waiver of appellate review does not implicate Article III, because it is the district court, not the court of appeals, that must exercise supervision over the magistrate, and the waiver rule does not elevate the magistrate from an adjunct to the functional equivalent of an Article III judge. Nor does the waiver rule violate the Due Process Clause of the Fifth Amendment. Petitioner's statutory right of appeal was not denied; it was merely conditioned upon the filing of a piece of paper. Pp. 474 U. S. 153-155.
728 F.2d 813, affirmed.
MARSHALL, J., delivered the opinion of the Court, in which BURGER, C.J., and WHITE, POWELL, REHNQUIST, and O'CONNOR, JJ., joined. BRENNAN, J., filed a dissenting opinion, in which BLACKMUN, J., joined, post, p. 474 U. S. 156. STEVENS, J., filed a dissenting opinion, post, p. 474 U. S. 157.
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