explaining that when a habeas petition presents both a question of procedural default and a merits issue, the procedural-bar question should ordinarily be considered first; however, where the procedural issue presents complicated issues of state law, and the merits question is easily resolvable against the petitioner, judicial economy counsels giving the merits question priority
How later courts described this case
- explaining that when a habeas petition presents both a question of procedural default and a merits issue, the procedural-bar question should ordinarily be considered first; however, where the procedural issue presents complicated issues of state law, and the merits question is easily resolvable against the petitioner, judicial economy counsels giving the merits question priority
- finding it "plain ... that a jurist considering all the relevant material ... could reasonably have reached a conclusion contrary to our holding in" Espinosa v. Florida, 505 U.S. 1079, 112 S.Ct. 2926, 120 L.Ed.2d 854 (1992) (per curiam), where "both before and after [petitioner's] conviction became final, every court decision we are aware of did so"
- explaining that “the procedural-bar issue . . . ordinarily should be” resolved first, but addressing the merits is appropriate where the underlying issues “[a]re easily resolvable against the habeas petitioner, whereas the procedural-bar issue involved complicated issues of state law.”
- stating that bypassing procedural questions to reach the merits of a habeas petition is justified in rare situations, “for example, if the [underlying issues] are easily resolvable against the habeas petitioner, whereas the procedural bar issue involved complicated issues of state law”
Written by the judges who cited it.
The opinion
Justice O’Connor,
dissenting.
Although I agree with much of the reasoning set forth in Part II of the Court’s opinion, I disagree with its disposition of the case. I would instead vacate the judgment of the Court of Appeals and remand the case so that the Court of Appeals might consider the procedural bar issue in the first instance.
The Court holds that, as a general practice, a federal ha-beas court should consider whether the relief a habeas petitioner requests is a “new rule” under Teague v. Lane, 489 U. S. 288 (1989), only after resolving the State’s argument that his claim is procedurally barred. Ante, at 525. Usu *547 ally, then, when a federal habeas court has before it contentions that a petitioner’s claim is barred both on state procedural grounds and because the petitioner seeks to rely on a “new rule” under Teague , the court should consider the Teague question only after the procedural bar issue has been resolved in the petitioner’s favor. As the Court recognizes, addressing the procedural bar issue first avoids unnecessary consideration of constitutional questions and accords fitting respect to the State’s procedural rules, which are indispensable to the administration of its criminal justice system. Ante, at 524-525.
With this much of the Court’s opinion I agree. Of course, there may be exceptions to the rule that the procedural bar issue should be resolved first. One case might be where the procedural bar question is excessively complicated, but the Teague issue can be easily resolved. The Court of Appeals here gave no reason for its failure to consider the Florida Supreme Court’s determination that petitioner’s claim based on Espinosa v. Florida, 505 U. S. 1079 (1992) (per curiam), was procedurally barred. Indeed, the Court of Appeals did not even discuss the state court’s holding, let alone decide that resolution of the procedural bar issue would be inappropriate in this case. I see no reason to think resolution of the procedural bar question would be especially troublesome, nor do I see any other reason for the Court of Appeals’ failure to give priority to the State’s argument that an independent and adequate state ground barred petitioner’s Espinosa claim.
Accordingly, I would remand the case to the Court of Appeals for it to resolve the procedural bar issue. As the Court points out, the Court of Appeals is better suited to evaluating matters of state procedure than are we. Ante, at 525. In my view, then, it is premature to address the State’s contention that petitioner’s Espinosa claim is barred on Teague grounds. Nevertheless, since the Court reaches the question, I wish to express my agreement with Justice Stevens’ resolution of the Teague issue.