Kaufman v. United States, 394 U.S. 217 (1969)

Kaufman v. United States

No. 53

Argued November 19, 1968
Decided March 24, 1969
394 U.S. 217

CERTIORARI TO THE UNITED STATES COURT OF APPEALS

FOR THE EIGHTH CIRCUIT

Syllabus

Petitioner was tried and convicted of a federal crime. His only defense was insanity. After his conviction was upheld on appeal, petitioner sought post-conviction relief under 28 U.S.C. § 2255, and included a claim that the finding of sanity was based upon the improper admission of illegally seized evidence. The District Court, after an evidentiary hearing, denied relief. Petitioner’s applications to the District Court and the Court of Appeals for leave to appeal in forma pauperis were denied, both courts adhering to the view followed by the Court of Appeals that unlawful search and seizure claims

are not proper matters to be presented by a motion to vacate sentence under § 2255 but can only be properly presented by appeal from the conviction.

Held: A claim of unconstitutional search and seizure is cognizable in a proceeding under 28 U.S.C. § 2255. Pp. 221-231.

(a) Unconstitutional restraints "may be challenged on federal habeas corpus even though imposed pursuant to the conviction of a federal court of competent jurisdiction," Fay v. Noia, 372 U.S. 391, 409 (1963), and the same principle applies in a proceeding under § 2255, which revised the post-conviction procedure for federal prisoners but did not reduce the scope of habeas corpus relief. Pp. 221-222.

(b) Post-conviction relief for prisoners’ constitutional claims is not limited by the rule that collateral review is not available to correct errors of law. P. 223.

(c) Federal post-conviction relief is available to both state and federal prisoners to protect constitutional rights relating to the criminal trial process (including the right of a defendant not to have unconstitutionally obtained evidence admitted against him at trial), and the circumstances under which a federal court must review constitutional claims of federal prisoners in a § 2255 proceeding are the same as those requiring habeas corpus review of constitutional claims of state prisoners, see Townsend v. Sain, 372 U.S. 293, 313 (1963), except that a § 2255 court need not be concerned with the adequacy of the underlying federal rules of procedure. Pp. 225-227.

(d) Considerations of finality of litigation have no greater weight with respect to federal prisoners seeking § 2255 relief than with respect to state prisoners seeking federal habeas corpus relief. P. 228.

(e) Petitioner’s insanity defense, like any other defense, cannot be prejudiced by the admission of illegally seized evidence. P. 230.

Reversed and remanded.