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Supreme Court finds state procedural rules 'adequate ground' for barring habeas review

[JURIST] The US Supreme Court [official website; JURIST news archive] on Tuesday ruled [opinion, PDF] in Beard v. Kindler [Cornell LII backgrounder; JURIST report] that a state procedural rule is not automatically "inadequate" to bar federal habeas review under the adequate state ground doctrine. The case arose when the Pennsylvania courts applied the state's fugitive forfeiture rule and concluded that defendant Joseph Kindler waived his right to seek appellate review, dismissing his appeal without reaching the merits of his claims. The Court vacated the decision of the US Court of Appeals for the Third Circuit, which had affirmed [opinion, PDF] the district court's grant of federal habeas relief. Chief Justice John Roberts wrote for the Court:

We hold that a discretionary state procedural rule can serve as an adequate ground to bar federal habeas review. Nothing inherent in such a rule renders it inadequate for purposes of the adequate state ground doctrine. To the contrary, a discretionary rule can be "firmly established" and "regularly followed" — even if the appropriate exercise of discretion may permit consideration of a federal claim in some cases but not others.

Justice Samuel Alito took no part in the consideration or decision of the case. Justice Anthony Kennedy filed a concurring opinion, joined by Justice Clarence Thomas.

The adequate state ground doctrine bars federal court jurisdiction in cases decided by a state court based on both federal and non-federal law if the state ground for the decision is adequate to support the judgment and is independent of federal law.

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