Taylor v. Alabama, 335 U.S. 252 (1948)
Taylor v. Alabama
No. 721
Argued April 30 and May 3, 1948
Decided June 21, 1948
335 U.S. 252
CERTIORARI TO THE SUPREME COURT OF ALABAMA
Syllabus
1. The Alabama procedure, whereby a trial court of that State, by writ of error coram nobis, may set aside its own judgment in a criminal case because of an error of fact not apparent on the common law record, is a procedure long recognized by the common law, and constitutes due process of law under the Fourteenth Amendment. Pp. 254, 259-261.
2. In requiring that permission of the state supreme court be obtained by petitioner before filing such a petition for writ of error coram nobis in a trial court, where the trial court’s judgment already has been affirmed by such supreme court, the procedure of the State is in accordance with long established common law practice, and constitutes due process of law under the Fourteenth Amendment. Pp. 254-255, 261.
3. In a trial in a state court of Alabama in which he was represented by competent counsel acceptable to him, did not testify in his own defense, and made no claim that his confessions and admissions introduced in evidence were coerced, and in which testimony was introduced as to his previous statement that his confessions and admissions had not been coerced, petitioner was convicted of rape and sentenced to death. On appeal, the Supreme Court of Alabama affirmed. Thereafter, through new counsel, he petitioned the Supreme Court of Alabama for an order granting him the right to file a petition in the trial court for writ of error coram nobis, claiming that the confessions and admissions used against him at the trial had been coerced, and that, through fear of further reprisals, he had falsely told his own trial counsel the contrary. After argument and upon consideration of the entire record, including that in the trial court and the affidavits filed in support of and in opposition to the petition, but without any statement from petitioner’s trial counsel, the Supreme Court of Alabama found that the averments of the petition were unreasonable, that there was no probability of truth contained therein, and that the proposed attack upon the judgment was not meritorious. It accordingly denied the petition.
Held: In so doing, it did not deny petitioner due process of law under the Fourteenth Amendment. Pp. 261-272.
(a) The issue before this Court is limited to a determination of whether, under all the circumstances, the action of the Supreme Court of Alabama in denying permission for the petitioner to file his petition not merely had committed an error, but had deprived the petitioner of life or liberty without due process of law. Pp. 261-262.
(b) In passing upon the petition, the Supreme Court of Alabama was not bound to accept the allegations of the petition at face value. That court was called upon to decide not only whether, if true, it presented a meritorious ground for setting aside its previous judgment, but, in its supervisory capacity over the enforcement of the law, to determine also the reasonableness of the allegations made in the petition and the probability or improbability of their truth. P. 262.
(c) The petition and the affidavits filed in its support must be tested for their reasonableness, the probability of their truth, the effectiveness of the attack they make on the original judgment, and their relationship to the general enforcement of law with justice to all -- in the light of the entire record already made in the case. Pp. 264-265.
(d) In the light of the entire record, the construction given to it by the Supreme Court of Alabama, and that court’s finding that the averments of the petition were unreasonable, that there was no probability of truth contained therein, and that the proposed attack upon the judgment was not meritorious, and in recognition of that court’s supervisory capacity over the procedure in the criminal trials of that State, it cannot be said that the action of the Supreme Court of Alabama in denying the petition was such an arbitrary one as in itself to amount to deprivation of due process of law. Pp. 265-272.
249 Ala. 667, 32 So.2d 659, affirmed.
After petitioner had been convicted of rape and sentenced to death and his conviction had been affirmed by the Supreme Court of Alabama (249 Ala. 130, 30 So.2d 256), he petitioned the Supreme Court of Alabama for permission to file a petition for writ of error coram nobis in the trial court, claiming for the first time that his confessions and admissions introduced in evidence at the trial had been coerced. The Supreme Court of Alabama denied the petition. 249 Ala. 667, 32 So.2d 659. This Court granted certiorari. 333 U.S. 866. Affirmed, p. 272.