Baldwin v. Reese Case Brief

Facts of the Case

“An accused was convicted, in an Oregon state court, on charges of kidnapping and attempted sodomy. After the accused was unsuccessful on direct appeal, lower state courts denied him collateral relief. The accused then petitioned for discretionary review in the Oregon Supreme Court. This petition asserted, among other matters, that the accused had received “ineffective assistance of both trial court and appellate court counsel.” While the petition alleged that trial counsel’s conduct had violated several provisions of the federal Constitution, the petition did not explicitly say that its appellate-assistance words referred to a federal-law claim. The Oregon Supreme Court denied review. Subsequently, the accused sought habeas corpus relief in the United States District Court for the District of Oregon, and included a federal-law claim of ineffective assistance of appellate counsel. However, the district court ruled that the accused had not fairly presented his appellate-assistance claim to the higher state courts and denied the request for relief. On appeal, the United States Court of Appeals for the Ninth Circuit reversed and ordered a remand, expressing the view that the accused had satisfied the “fair presentation” requirement, on the basis that (1) the justices of the Oregon Supreme Court had had the opportunity to read the lower state court decision claimed to be in error