Court: Supreme Court of the United States; April 1, 1935; Federal Supreme Court; Federal Appellate Court
Haywood Patterson, indicted alongside Clarence Norris and seven other African American boys for rape in Jackson County, Alabama, faced multiple trials following a Supreme Court reversal of their convictions. After a mistrial, Patterson was retried in November 1933 and convicted again, with the state Supreme Court affirming the judgment. Patterson's defense filed motions to quash the indictment and the trial venire, citing systematic exclusion of African Americans from juries, which they argued violated the Fourteenth Amendment. These motions were similar to those presented in the Norris case, and both trials used the same evidence. The state contended that the federal question was not applicable, asserting that the state court's decision was based solely on state procedural grounds. The state Supreme Court had struck Patterson's bill of exceptions, which included evidence relevant to the motions to quash, ruling it was untimely. Consequently, the court did not address the federal question, leading to the current examination of whether the state court's judgment rested on sufficient non-federal grounds.
Under the Code of Alabama, a bill of exceptions must be filed within ninety days from the judgment date or the ruling on a motion for a new trial. After thirty days post-judgment, the court loses jurisdiction unless a motion to set aside the judgment or for a new trial is filed and continued for hearing. In this case, Patterson was found guilty on December 1, 1933, and sentenced to death on December 6, 1933. His bill of exceptions was filed on March 5, 1934, outside the permissible timeframe.
Patterson's counsel requested an extension to file a motion for a new trial, citing the need for a transcript, but this request was denied. The motion for a new trial was eventually filed on December 29, 1933, but the Attorney General moved to strike it, claiming it was filed after the court term expired on December 23, 1933. The trial judge agreed, leading to a ruling by the Supreme Court of Alabama that upheld this decision based on precedent, affirming that motions for new trials must be filed within the court term.
The Supreme Court also clarified that the bill of exceptions must be presented within ninety days from the judgment of guilty (December 1, 1933), not from the sentencing date (December 6, 1933). Therefore, the court concluded that the bill of exceptions was untimely, aligning with Alabama's long-standing legal precedent.
The failure to timely file a bill of exceptions does not automatically strip the state appellate court of jurisdiction. According to Alabama law, the court cannot independently strike a bill of exceptions for untimeliness; such action can only be taken upon a motion from a party or their attorney, and parties can waive this objection. Previous state court decisions have interpreted "waiver or consent" as a failure to move to strike at the time of appeal submission, obligating the court to grant such a motion when presented.
In this case, an important constitutional question was at stake, as it was linked to another appeal involving a similar indictment. The evidence for both cases was identical and presented the same day. There was a potential misunderstanding regarding the timing of the bill of exceptions due to a statement by the Attorney General, which might have misled the defense regarding the filing's timeliness.
The decisions for both cases were released simultaneously, with the state court ruling against the constitutional challenge in the Norris case, which likely influenced its decision to strike the bill of exceptions in the Patterson case. There are concerns that the court would have treated Patterson's case differently had the constitutional question been resolved favorably for Norris. Given the unique circumstances of the cases, including their interconnectedness and the gravity of the outcomes, the court may have felt compelled to provide appropriate relief rather than dismissing the bill of exceptions.
Applying a judicial ruling to a new, serious situation that was not considered at the time of the ruling can be problematic. It is essential for the state court to assess its powers in light of recent developments, and this opportunity should not be denied. The appellate court has the authority to correct errors in the judgment and make decisions based on what justice requires, which includes considering any changes in fact or law that have occurred since the original judgment. Such changes may warrant vacating the judgment and remanding the case to the state court for further action. This approach does not constitute a review of the state court's decision on a nonfederal question but focuses on new matters that impact the case's proper resolution. Consequently, the judgment is vacated, and the case is remanded to the state court for additional proceedings. Justice McReynolds did not participate in this case's consideration or decision.
