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Sumner v. Mata, 449 U.S. 539 (1981)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Sumner v. Mata, 449 U.S. 539 (1981)
Sumner v. Mata, 449 U.S. 539 (1981) No. 79-1601 Argued December 9, 1980 Decided January 21, 1981 449 U.S. 539
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT
Syllabus
Respondent was convicted of first-degree murder in a California state court after a trial at which eyewitnesses identified him as participating in the murder. The California Court of Appeal affirmed, rejecting respondent’s contention, made for the first time, that the pretrial photographic identification employed by the police violated his Fourteenth Amendment due process rights. The court concluded upon review of the trial record that "the facts of the present case" did not adequately support respondent’s claim. Respondent did not seek review by the California Supreme Court, but later raised the pretrial identification issue in state habeas corpus proceedings, which resulted in denial of relief by the trial court, the California Court of Appeal, and the California Supreme Court. Respondent then sought federal habeas corpus relief pursuant to 28 U.S.C. $ 2254, but the Federal District Court denied the petition. The United States Court of Appeals, employing the same standard used by the state courts, reversed. On the basis of findings considerably at odds with the findings of the California Court of Appeal, the United States Court of Appeals, after reviewing the state court trial record, concluded that the photographic identification was so impermissibly suggestive as to give rise to a very substantial likelihood of irreparable misidentification. The Court of Appeals’ opinion did not refer to 28 U.S.C. $ 2254(d), which provides that, in federal habeas corpus proceedings instituted by a state prisoner, "a determination after a hearing on the merits of a factual issue" made by a state court of competent jurisdiction and "evidenced by a written finding, written opinion, or other reliable and adequate written indicia, shall be presumed to be correct" unless one of seven specified conditions is found to exist or unless the habeas court concludes that the relevant state court determination "is not fairly supported by the record."
Held: The Court of Appeals did not properly analyze respondent’s challenge to his state court conviction, given the limited nature of the review provided federal courts by § 2254. Pp. 543-552.
(a) Section 2254(d) applies to factual determinations made by state courts, whether the court be a trial court or an appellate court. The California Court of Appeal held a "hearing" within the meaning of § 2254(d), since both respondent and the State were formally before the court, respondent was given an opportunity to be heard, and his claim received plenary consideration. The interest in federalism recognized by Congress in enacting § 2254(d) requires deference by federal courts to factual determinations of all state courts, and this is true particularly in a case such as this, where a federal court makes its determination based on the identical record that was considered by the state appellate court, and where there was no reason for the state trial court to consider the issue because respondent failed to raise it at that level. Pp. 545-547.
(b) Given the applicability of § 2254(d) to the present case, it is not apparent that the Court of Appeals, whose opinion gave no indication that § 2254 was even considered, applied the "presumption of correctness" which is mandated by the statute to the factual determinations made by the California state court. When Congress provided in § 2254(d) that a habeas court could not dispense with the "presumption of correctness" embodied therein unless it concluded that the factual determinations were not supported by the record, it contemplated at least some reasoned written references (not present here) to § 2254(d) and the state court findings. Pp. 547-549.
(c) In providing in § 2254(d) that, absent any of the enumerated factors, the burden rests on the habeas petitioner to establish "by convincing evidence that the factual determination of the State court was erroneous," Congress meant to insure that a state finding not be overturned merely on the basis of the usual "preponderance of the evidence" standard. To ensure that this mandate of Congress is enforced, a federal habeas court should include in its opinion granting the writ the reasoning which led it to conclude that any of the first seven factors were present, or the reasoning which led it to conclude that the state finding was "not fairly supported by the record." Pp. 550-552.
611 F.2d 754, vacated and remanded.
REHNQUIST, J., delivered the opinion of the Court, in which BURGER, C.J., and STEWART, WHITE, and POWELL, JJ., joined. BLACKMUN, J., filed a statement concurring in the result, post, p. 552. BRENNAN, J., filed a dissenting opinion, in which MARSHALL and STEVENS, JJ., joined, post, p. 552
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Chicago: U.S. Supreme Court, "Syllabus," Sumner v. Mata, 449 U.S. 539 (1981) in 449 U.S. 539 449 U.S. 540–449 U.S. 541. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=F1IM8A2I4MRBZSJ.
MLA: U.S. Supreme Court. "Syllabus." Sumner v. Mata, 449 U.S. 539 (1981), in 449 U.S. 539, pp. 449 U.S. 540–449 U.S. 541. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=F1IM8A2I4MRBZSJ.
Harvard: U.S. Supreme Court, 'Syllabus' in Sumner v. Mata, 449 U.S. 539 (1981). cited in 1981, 449 U.S. 539, pp.449 U.S. 540–449 U.S. 541. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=F1IM8A2I4MRBZSJ.
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