McCleskey v. Zant
McCleskey v. Zant is a significant U.S. Supreme Court case that addressed the procedural requirements for filing federal habeas corpus petitions by death row inmates. In the context of the 1960s and 1970s, the Court had initially broadened the ability for inmates to challenge their state convictions through multiple habeas petitions, raising various constitutional claims. However, the Court's stance shifted under Chief Justice William H. Rehnquist, leading to a stricter approach against procedural delays. In this case, Warren McCleskey's second habeas petition was rejected by a 6-3 vote, with the Court establishing that defendants must include all constitutional arguments in their initial petitions.
Justice Anthony M. Kennedy articulated the "cause and prejudice" standard, which requires defendants to demonstrate both that an earlier claim was omitted for a legitimate reason outside of their control and that this omission caused actual prejudice. The ruling also introduced stringent limitations on successive petitions, allowing exceptions only for errors deemed fundamentally unjust, such as those affecting the conviction of an innocent person. This case paved the way for further legislative measures, notably the Antiterrorism and Effective Death Penalty Act of 1996, which tightened the rules surrounding habeas corpus petitions even more. The implications of McCleskey v. Zant resonate in ongoing discussions about the rights of inmates and the administration of justice in capital cases.
McCleskey v. Zant
Date: April 16, 1991
Citation: 499 U.S. 467
Issue:Habeas corpus
Significance: The Supreme Court significantly restricted the conditions under which federal courts were allowed to accept second habeas corpus petitions by state prisoners sentenced to death.
During the 1960’s the Court had expanded the scope of federal habeas corpus reviews of state criminal convictions. One consequence was that death row inmates were able to file several habeas corpus petitions, each raising a different constitutional claim. After William H. Rehnquist became chief justice, however, the Court grew intolerant of long procedural delays in such cases. Following the Court’s rejection of Warren McCleskey’s first challenge to his death sentence, his lawyers filed a second habeas corpus petition, alleging that prosecutors at his trial had used incriminating statements that were made without assistance of counsel.
By a 6-3 vote, the Court rejected the claim. Justice Anthony M. Kennedy, in the opinion for the majority, insisted that a defendant must include all of his constitutional arguments in the first petition to the federal courts. To prevent abuse, the Court adopted the cause and prejudice standard, requiring the defendant to show that he or she had not raised the claim earlier because of a cause beyond his or her control and to demonstrate that the alleged errors resulted in actual prejudice. Exceptions to the cause and prejudice standard would be allowed only when the defendant could show that an error was so fundamental that it had resulted in the conviction of an innocent person.
In the Antiterrorism and Effective Death Penalty Act of 1996, Congress made it even more difficult for defendants to file second habeas corpus petitions. The Court upheld the constitutionality of the statute in Felker v. Turpin (1996).