Murray v. Carrier

Justice Brennan,

with whom Justice Marshall joins, dissenting.*

I

A

Like the Great Writ from which it draws its essence, see Engle v. Isaac, 456 U. S. 107, 126 (1982), the root principle underlying 28 U. S. C. §2254 is that government in a civilized society must always be accountable for an individual’s imprisonment; if the imprisonment does not conform to the fundamental requirements of law, the individual is entitled to his immediate release. Of course, the habeas corpus relief available under §2254 differs in many respects from its common-law counterpart. Most significantly, the scope of the writ has been adjusted to meet changed conceptions of the kind of criminal proceedings so fundamentally defective as to make imprisonment under them unacceptable. See, e. g., Moore v. Dempsey, 261 U. S. 86 (1923); Johnson v. *517Zerbst, 304 U. S. 458 (1938); Waley v. Johnston, 316 U. S. 101 (1942); Brown v. Allen, 344 U. S. 443 (1953); Fay v. Noia, 372 U. S. 391 (1963). At the same time, statutory ha-beas relief has become more difficult to obtain as a result of certain procedural limitations created to reflect the unique character of our federal system. See, e. g., 28 U. S. C. § 2254(b) (exhaustion of state remedies).

The “cause and prejudice” rule of Wainwright v. Sykes, 433 U. S. 72 (1977), is one such procedural limitation. A judicially created restriction that is not required — or even suggested — by the habeas statute itself, the “cause and prejudice” rule is sometimes thought to represent an application of the familiar principle that this Court will decline to review state-court judgments which rest on independent and adequate state grounds, even where those judgments also decide federal questions. To be sure, the fact that a state-court judgment rests on a purely procedural ground may preclude direct Supreme Court review of that judgment where, as applied, the state procedural rule furthers a legitimate interest. See Henry v. Mississippi, 379 U. S. 443, 447-449 (1965). However, in Fay v. Noia, supra, the doctrine that procedural defaults may constitute an independent and adequate state-law ground was held not to limit the jurisdiction of the federal courts under the habeas corpus statute. Id., at 426-435. That conclusion has subsequently been reaffirmed on several occasions. See Francis v. Henderson, 425 U. S. 536, 538 (1976); Wainwright v. Sykes, supra, at 83; Reed v. Ross, 468 U. S. 1, 9 (1984).

Despite the existence of federal power to entertain a ha-beas petition in the face of a procedural default, the Court in Fay v. Noia' acknowledged “a limited discretion” in the federal court to refuse to exercise its jurisdiction on behalf of “an applicant who has deliberately by-passed the orderly procedure of the state courts and in doing so has forfeited his state court remedies.” 372 U. S., at 438. This exception was recognized “[a]s a matter of comity,” Wainwright v. Sykes, *518supra, at 83, in order to accord state courts and state procedures the respect due them in a federal system. See Reed v. Ross, supra, at 10-11; Engle v. Isaac, supra, at 126-129; Francis v. Henderson, supra, at 539. Thus, the withholding of federal habeas jurisdiction for certain procedurally defaulted claims is a form of abstention. Cf., e. g., Younger v. Harris, 401 U. S. 37 (1971); Burford v. Sun Oil Co., 319 U. S. 315 (1943).1

The general principles for deciding whether abstention is proper are well established. “Abstention from the exercise of federal jurisdiction is the exception, not the rule.” Colorado River Water Conservation District v. United States, 424 U. S. 800, 813 (1976). As we have previously noted, ‘“[t]he doctrine of abstention... is an extraordinary and narrow exception to the duty of a District Court to adjudicate a controversy properly before it.’ ” Ibid, (quoting Allegheny County v. Frank Mashuda Co., 360 U. S. 185, 188 (1959)). Where Congress has granted individuals the right to a federal forum, we cannot deny that right simply because we disagree with Congress’ determination that federal review is desirable. Rather, abstention must be justified by weighty concerns of comity and judicial administration, and even then abstention should not be ordered without a careful balancing of those concerns against concerns favoring the exercise of federal jurisdiction. Cf. Steffel v. Thompson, 415 U. S. 452, *519460-462 (1974); Wooley v. Maynard, 430 U. S. 705, 709-712 (1977); Doran v. Salem Inn, Inc., 422 U. S. 922 (1975).

These principles apply as much to abstention from the exercise of federal habeas corpus jurisdiction as to any other area of federal jurisdiction. For while Congress did leave the federal courts considerable latitude to shape the availability of the writ, Congress did not issue this Court a mandate to sharpen its skills at ad hoc legislating. The same rules of construction that guide interpretation of other statutes apply to the federal habeas corpus statute. Accordingly, the decision whether to direct federal courts to withhold habeas jurisdiction clearly conferred upon them by Congress must be made with the understanding that such abstention doctrines constitute “‘extraordinary and narrow’” exceptions to the “virtually unflagging obligation” of federal courts to exercise their jurisdiction, Colorado River Water Construction District v. United States, supra, at 813, 817 (quoting Allegheny County v. Frank Mashuda Co., supra, at 188). Moreover, judicial renouncement of federal habeas corpus jurisdiction can take place only after careful consideration of the competing interests militating for and against the exercise of federal jurisdiction, and the presumption is heavily in favor of exercising federal jurisdiction. 424 U. S., at 817.

B

The competing interests implicated by a prisoner’s petition to a federal court to review the merits of a procedurally defaulted constitutional claim are easily identified. On the one hand, “there is Congress’ expressed interest in providing a federal forum for the vindication of the constitutional rights of state prisoners.” Reed v. Ross, 468 U. S., at 10. In enacting §2254, “Congress sought to ‘interpose the federal courts between the States and the people, as guardians of the people’s federal rights — to protect the people from unconstitutional action.’” Ibid, (quoting Mitchum v. Foster, 407 U. S. 225, 242 (1972)). This interest is at its strongest *520where the state court has declined to consider the merits of a constitutional claim, for without habeas review no court will ever consider whether the petitioner’s constitutional rights were violated.

These interests must be weighed against the State’s interest in maintaining the integrity of its rules and proceedings, an interest that would be undermined if the federal courts were too free to ignore procedural forfeitures in state court. 468 U. S., at 10. The criminal justice system in each State is structured both to determine the guilt or innocence of defendants and to resolve all questions incident to that determination, including the constitutionality of the procedures leading to the verdict. Each State’s complement of procedural rules facilitates this process by “channeling, to the extent possible, the resolution of various types of questions to the stage of the judicial process at which they can be resolved most'fairly and efficiently.” Ibid. Procedural default rules protect the integrity of this process by imposing a forfeiture sanction for failure to follow applicable state procedural rules, thereby deterring litigants from deviating from the State’s scheme. Generally, the threat of losing the right to raise a claim in state proceedings will be sufficient to ensure compliance with the State’s procedural rules: a defendant loses nothing by raising all of his claims at trial since the state-court judgment will have no res judicata effect in later habeas proceedings, Brown v. Allen, 344 U. S. 443 (1953), while he retains the possibility of obtaining relief in the state courts. See Wainwright v. Sykes, 433 U. S., at 103-104, and n. 5 (Brennan, J., dissenting). Nonetheless, to the extent that federal habeas review of a procedurally defaulted claim is available, the broad deterrent effect of these procedural default rules is somewhat diminished.2

*521The Court’s view of how properly to balance these competing concerns has changed over time. In Fay v. Noia, we concluded that the State’s interest “in an airtight system of forfeitures” was generally insufficient to require federal courts to refrain from exercising their habeas jurisdiction. 372 U. S., at 432, 438-440. We held that federal courts should refuse to exercise their jurisdiction only “[i]f a habeas applicant . . . understanding^ and knowingly forewent the privilege of seeking to vindicate his federal claims in the state courts, whether for strategic, tactical, or any other reasons that can fairly be described as the deliberate by-passing of state procedures.” Id., at 439. This holding sensibly ac*522commodated the competing interests described above: on the one hand, the State’s interest in preventing litigants from ignoring its procedural rules is at its strongest where the decision not to raise a claim is made knowingly and deliberately; correspondingly, the prisoner’s entitlement to a federal forum is at its weakest since it may well be only the deliberate failure to submit the claim to the state courts that has necessitated federal review. Under these circumstances, the affront to comity principles is at its greatest: by its indifference in entertaining the petition to the prisoner’s trial strategy, the federal court in effect ratifies the deliberate circumvention of state procedural rules. If refusal to exercise federal habeas power to upset a state-court conviction is ever appropriate, it is under circumstances such as these.

The Court struck a somewhat different balance 14 years later when it revisited the question of withholding federal ha-beas jurisdiction of procedurally defaulted claims in Wainwright v. Sykes. Police officers testified at Sykes’ trial about inculpatory statements he had made in their presence. No objection was made at the time this testimony was offered, which meant, under a state procedural rule, that any objections were forfeited. Subsequently, Sykes filed a petition for a writ of habeas corpus in the federal court, asserting that his statements were inadmissible because he had not understood his Miranda warnings. The District Court granted the writ, but this Court reversed, holding that the District Court should never have entertained Sykes’ habeas petition at all. Rejecting “the sweeping language of Fay v. Noia,” the Court concluded that Fay’s deliberate bypass test paid insufficient respect to the State’s interests — viewed through the prism of federalism and comity concerns — in seeing its procedural default rules enforced. 433 U. S., at 87-88. The Court held instead that federal courts should decline to exercise their habeas jurisdiction absent a stronger showing by the prisoner that federal review is appropriate. Specifically, the Court held that federal habeas review of a procedurally defaulted claim should ordinarily be withheld unless the peti*523tioner shows “cause” for the procedural default and “prejudice” to his case from the underlying error. Id., at 87.

The Court left open “for resolution in future decisions the precise definition of the ‘cause’-and-‘prejudice’ standard,” ibid., noting only that “it is narrower than the standard set forth,” ibid., in Fay v. Noia, and suggesting that, as such, it would provide a better balance between the interests of a petitioner and those of the State, id., at 88-91. I thought then that Wainwright v. Sykes was wrongly decided, and I continue to believe so for the reasons I stated there and in subsequent cases. See Wainwright v. Sykes, supra, at 99-118 (Brennan, J., dissenting); Engle v. Isaac, 456 U. S., at 137-151 (Brennan, J., dissenting); United States v. Frady, 456 U. S. 152, 178-187 (1982) (Brennan, J., dissenting). But at least the Court in Wainwright v. Sykes was prudent enough to leave the task of defining “cause” and “prejudice” to subsequent cases. For, to the extent that the availability of federal habeas review of procedurally defaulted claims turns on the cause-and-prejudice test,3 then it is in the context of giving that test meaning that the Court must undertake the careful evaluation of the interests of the State and defendant that is required to determine whether federal courts may properly decline to exercise jurisdiction conferred upon them by Congress.

II

A

The particular question we must decide in this case is whether counsel’s inadvertent failure to raise a substantive claim of error can constitute “cause” for the procedural de*524fault. Wainwright v. Sykes held that defense counsel’s tactical decision to bypass a state procedure does not constitute cause. 433 U. S., at 91, n. 14; see also ante, at 485; Reed v. Ross, 468 U. S., at 13. That result may arguably be defended on grounds similar to those which justified the result in Fay v. Noia, i. e., that the deterrent interests underlying the State’s procedural default rule are at their apogee where counsel’s decision to bypass a state procedure is deliberate. However, to say that the petitioner should be bound to his lawyer’s tactical decisions is one thing; to say that he must also bear the burden of his lawyer’s inadvertent mistakes is quite another. Where counsel is unaware of a claim or of the duty to raise it at a particular time, the procedural default rule cannot operate as a specific deterrent to noncompliance with the State’s procedural rules. Consequently, the State’s interest in ensuring that the federal court help prevent circumvention of the State’s procedural rules by imposing the same forfeiture sanction is much less compelling. To be sure, applying procedural default rules even to inadvertent defaults furthers the State’s deterrent interests in a general sense by encouraging lawyers to be more conscientious on the whole. However, as the Court has pointed out in another context, such general deterrent interests are weak where the failure to follow a rule is accidental rather than intentional. See United States v. Leon, 468 U. S. 897, 908-917 (1984).

I believe that this incremental state interest simply is not sufficient to overcome the heavy presumption against a federal court’s refusing to exercise jurisdiction clearly granted by Congress. This is especially so where the petitioner has satisfied the prejudice prong of the Wainwright v. Sykes test. That is, where a petitioner’s constitutional rights have been violated and that violation may have affected the verdict, a federal court should not decline to entertain a habeas petition solely out of deference to the State’s weak interest in punishing lawyers’ inadvertent failures to comply with state *525procedures. I would therefore hold that “cause” is established where a procedural default resulted from counsel’s inadvertence, and I respectfully dissent from the Court’s decisions in both Murray v. Carrier, No. 84-1554, and Smith v. Murray, No. 85-5487.4

B

Even if I did not believe that this difference in the State’s interests was sufficient to require holding that counsel’s inadvertence constitutes cause, there is an additional difference in the defendant’s interests that compels this conclusion in Smith v. Murray: the fact that it is a capital case. To the extent that, as I have argued above, the definition of cause requires consideration of the interests of the defendant as well as of the State, it strikes me as cruelly unfair to bind a defendant to his lawyer’s inadvertent failure to prevent prejudicial constitutional error — thus barring access to federal *526review — where the consequence to the defendant is death. With the understanding that “execution is the most irremediable and unfathomable of penalties; that death is different,” Ford v. Waimvright, ante, at 411; see also Woodson v. North Carolina, 428 U. S. 280, 305 (1976) (opinion of Stewart, Powell, and Stevens, JJ.), this Court has been particularly scrupulous in demanding that the proceedings which condemn an individual to death not be marred by constitutional error. Against this background of special concern, “comity” and “federalism” concerns simply do not require such an exercise of this Court’s discretion in capital cases.

[This opinion applies also to No. 85-5487, Smith v. Murray, Director, Virginia Department of Corrections, post, p. 527.]

There is one important difference between abstention in the habeas context and in other contexts. In our other abstention cases, federal jurisdiction has been withheld partly because of ongoing proceedings or the possibility of future proceedings in the state courts; in the habeas context, the state proceedings have already taken place and the petitioner’s federal claim has not been considered on the merits. If anything, however, this difference makes the practice of abstaining more suspect in the habeas context, and suggests that the federal courts should adhere even more closely to the principle — discussed in text — that abstention is a narrow exception to the general rule requiring federal courts to exercise power conferred upon them by Congress.

The Court has often suggested, as it does again today, that the “reduction in the finality of litigation” caused by habeas review justifies a broad construction of the cause-and-prejudice test. Ante, at 486-487 (citing Engle v. Isaac, 456 U. S. 107, 128 (1982)). In fact, “finality” concerns *521have no bearing on the question whether a federal court should refuse to exercise its habeas jurisdiction because of a procedural default. From the standpoint of the State’s finality interests, there is no difference whatever between making habeas review available after the state court has denied a claim on the merits, and making such review available after the state court has denied the claim on procedural default grounds. In both situations, the State has determined that the litigation is at an end, and the federal court has reopened the case to consider releasing the petitioner from custody. No one questions the availability of habeas relief where the state court has denied the claim on the merits. Accordingly, treating likes alike, such relief should also be available where the claim is denied because of a procedural default unless the State’s interest in enforcing its default rules requires a different result. General “finality” concerns simply are not relevant.

The same is true of the Court’s other habeas corpus bogeymen, such as the tendency of habeas review to detract from the importance of the trial as the “main event,” Wainwright v. Sykes, 433 U. S. 72, 90 (1977), and to frustrate the State’s “good-faith attempts to honor constitutional rights,” Engle v. Isaac, swpra, at 128. These “costs” are present whenever a claim has been denied by the state court on the merits in precisely the same way and to precisely the same extent as where that claim is denied on procedural default grounds. Indeed, if anything, these “costs” are present to a greater extent where a federal court reviews a constitutional claim that the state court has considered and rejected. Therefore, if federal jurisdiction is to be renounced where there has been a procedural default, it must be because of some particular need to enforce the State’s procedural default rules.

Although Wainwright v. Sykes held only that the cause-and-prejudice test should be applied to violations of contemporaneous-objection rules, subsequent eases have extended the cause-and-prejudice test well beyond that narrow holding. See Engle v. Isaac, 456 U. S. 107 (1982); United States v. Frady, 456 U. S. 152 (1982); Reed v. Ross, 468 U. S. 1 (1984). It is still an open question “whether counsel’s decision not to take an appeal at all” — the question presented on the facts of Fay v. Noia — is governed by the deliberate bypass rule or the cause-and-prejudice test. Ante, at 492.

1 do not mean to suggest by this that I accept the Court’s decision in Wainwright v. Sykes or that I think that a habeas petitioner should ever have to show “cause” and “prejudice” to gain access to the federal courts under § 2254. As noted above, I continue to believe that Wainwright v. Sykes represented an illegitimate exercise of this Court’s very limited discretion to order federal courts to decline to entertain habeas petitions. My point is simply that, even accepting the validity of Wainwright’s “cause and prejudice” test, the Court must still carefully balance the relevant interests, and, when this balancing is done properly, it is apparent that counsel’s inadvertence should constitute “cause.” Accordingly, I would affirm the decision of the Court of Appeals in Murray v. Carrier.

While reversing the holding of the Court of Appeals that counsel’s inadvertence establishes “cause,” the Court goes on to declare that “where a constitutional violation has probably resulted in the conviction of one who is actually innocent, a federal court may grant the writ even in the absence of a showing of cause for the procedural default.” Ante, at 496. Under such circumstances, the Court explains, “the principles of comity and finality that inform the concepts of cause and prejudice ‘must yield to the imperative of correcting a fundamentally unjust incarceration.’” Ante, at 495 (quoting Engle v. Isaac, supra, at 135). Although I believe that principles of “comity” and “finality” yield upon far less than a showing of actual innocence, because this inquiry represents a narrowing of the “cause and prejudice” test, I agree that it is proper.