RESPONDENT:Lincoln Isaac, et al.
LOCATION: Pickaway County Court of Appeals
DOCKET NO.: 80-1430
DECIDED BY: Burger Court (1981-1986)
LOWER COURT: United States Court of Appeals for the Sixth Circuit
CITATION: 456 US 107 (1982)
ARGUED: Dec 08, 1981
DECIDED: Apr 05, 1982
GRANTED: Apr 20, 1981
James R. Kingsley – on behalf of the Respondent Isaac
Richard L. Aynes – on behalf of Respondents Bell and Hughes
Simon B. Karas – on behalf of the Petitioner
Facts of the case
In 1974, Ohio enacted a statute that stated, while the burden to prove the defendant guilty beyond a reasonable doubt rested on the prosecution, the burden of proof for an affirmative defense rested on the defendant. From 1974 until 1976, Ohio state courts operated as though this statute did not affect Ohio’s traditional rule that a defendant had to prove an affirmative defense by a preponderance of the evidence. However, in 1976 the Supreme Court of Ohio found that the statute placed only the burden of production of such evidence — as opposed to the burden of persuasion — on the defendant, and jury instructions were altered accordingly.
The respondents, Lincoln Isaac, Kenneth Bell, and Howard Hughes, each had separate trials that occurred after the 1974 statute was put in place, but before the 1976 decision. At the time of their trials, none of the respondents objected to the jury instructions regarding how the jury should consider evidence of self-defense. The Ohio Criminal Code required defendants to raise any objections to jury instructions at the time the instructions are given. The respondents filed petitions in federal district courts for writs of habeas corpus and used the 1976 decision to challenge the jury instructions trial. The courts denied the writs. The U.S. Court of Appeals for the Sixth Circuit affirmed the convictions, and rejected the argument regarding the jury instructions because it had not been made at the time of the trial. The Ohio Supreme Court declined to review the case.
Can the respondents claim they are entitled to federal writs of habeas corpus where the Ohio courts refused to allow them to challenge Ohio state jury instructions after the fact?
Media for Engle v. Isaac
Audio Transcription for Opinion Announcement – April 05, 1982 in Engle v. Isaac
Warren E. Burger:
The opinions for the Court in Number 80-1430 and 80-1595 will be announced by Justice O’Connor.
Sandra Day O’Connor:
In clause 80-1430, Engle versus Isaac, the case comes to us on writ of certiorari to the United States Court of Appeals for the Sixth Circuit.
The case arises from three unrelated criminal convictions.
The three respondents were convicted by Ohio of voluntary manslaughter, murder and aggravated assault respectively.
At their trials, all three respondents claimed self-defense.
Without objections from the respondents, the trial judges instructed the juries that respondents bore the burden of proving this defense by a preponderance of the evidence.
After the Ohio courts affirmed the convictions, respondents sought federal writs of habeas corpus.
A fair reading of respondents’ habeas petitions informed by the manner in which the district judges themselves construed the petitions reveals that each respondent presented only one colorable constitutional claim to the district courts.
Respondents claim that the trial instructions requiring them to prove absence of self-defense by a preponderance of the evidence conflicted with Ohio’s constitutional duty to prove their guilt beyond a reasonable doubt. We do not consider the merits of that claim because respondents fail to present it properly to the Ohio courts.
Under Ohio law, respondents waived their objection to the self-defense instructions when they failed to object to those instructions at trial.
Five years ago, when Wainwright versus Sykes, we held that a state prisoner who waived the constitutional claim during state proceedings could not present that claim in a federal habeas petition unless he demonstrated cause for an actual prejudice from a default.
Because the cause and prejudice standard serves important interest in finality and on comity, we reaffirmed that ruling today.
We find that respondents have shown no cause for their procedural defaults.
We have reversed the judgments of the Court of Appeals for the Sixth Circuit and remanded the cases per proceedings consistent with the opinion.
Justice Blackmun concurs in the result.
Justice Stevens has filed an opinion concurring in part and dissenting in part.
Justice Brennan joined by Justice Marshall has filed a dissenting opinion.