Fay v. Noia
**Overview of Fay v. Noia**
Fay v. Noia is a significant Supreme Court case that addresses the rights of state prisoners regarding habeas corpus petitions. The Court, in a 6-3 decision led by Justice William J. Brennan, Jr., ruled that state prisoners could file habeas corpus petitions in federal court even if they did not meet state statute-of-limitation requirements. This decision marked a departure from previous rulings that mandated the exhaustion of state remedies through a petition for certiorari, a process that is often lengthy and rarely granted. The case arose from the conviction of Noia for murder, which was based on a coerced confession, an act that the Court had previously deemed unconstitutional. Despite acknowledging Noia's failure to file a timely appeal, the majority opinion emphasized the importance of due process, deeming the technicality insufficient to uphold the conviction. The dissenting justices expressed a different view, highlighting the complexities inherent in procedural due process. This ruling underscores the broader implications for the rights of prisoners and the accessibility of federal courts for addressing potential injustices in state legal proceedings.
Fay v. Noia
Date: March 18, 1963
Citation: 372 U.S. 391
Issue: Procedural due process
Significance: The Supreme Court upheld the right of those convicted of state offenses to use habeas corpus petitions in federal courts, notwithstanding minor time limitations in state law.
Justice William J. Brennan, Jr., wrote for the 6-3 majority, upholding the right of state prisoners to use habeas corpus petitions in federal courts even if they have failed to comply strictly with state statute-of-limitation provisions. Basically, the Supreme Court abandoned its earlier ruling that the exhaustion of state remedies had to include a petition to be heard by the Court (certiorari). Because so few certiorari petitions are granted and the process is so time-consuming, it is a burdensome requirement. In this case, defendant Noia had been convicted of murder with the use of a coerced confession in a state court despite the Court’s prior prohibition on the use of coerced confessions. The state admitted this and relied solely on Noia’s failure to file a timely appeal from the state appellate court, a technicality that the Court did not find compelling under the circumstances, although it did satisfy the dissenting justices: Tom C. Clark, John M. Harlan II, and Potter Stewart.
