Federal Courts—Fall 2020

Habeas Corpus Problem (Cognizable Claims)

The U.S. Supreme Court’s decision in Miranda v. Arizona (1966) holds that if police take
a suspect into custody and question him without giving the “Miranda warnings” (“you have the
right
to remain silent,” etc.), the suspect’s statements may not be admitted in evidence. However, in
New
York v. Quarles (1984), the Supreme Court held that police may question a suspect without
giving
the Miranda warnings if the questioning is reasonably necessary to protect public safety.

In 2019, police in Minnesota arrest David, a troubled teenager, whom they suspect of
planning a mass shooting at his school. The police take David to the police station and, without
giving him the Miranda warnings, ask him whether he has any accomplices who are still at large.
David says yes and names two friends of his.

David’s trial in state court for conspiracy to commit murder is held in May 2020. David’s
statement that he had accomplices is crucial to the prosecution’s case. David objects to the
admission of this statement on the basis of Miranda. He does not question the validity of the
Quarles exception to Miranda, but he argues that his case is not within the exception because the
police questioning was not necessary to protect public safety. The alleged murder plot, he argues,
was so vague and theoretical that there was never any real threat to public safety. The trial judge
holds that the Quarles exception to Miranda applies. David’s statement is admitted in evidence.

David is convicted and sentenced to 15 years in prison. In February 2021, David’s

conviction is affirmed by a mid-level Minnesota state appellate court. David appeals to the
Supreme Court of Minnesota. In June 2021, the U.S. Supreme Court, in the case of Sanchez v.
New Mexico, overrules Quarles and holds that there is no “public safety” exception to Miranda.
In December 2021,
Minnesota’s Supreme Court rules that David cannot rely on the U.S. Supreme Court’s decision
in
Sanchez, because state law does not allow a defendant to raise an argument on appeal that was
not
raised at trial. David’s conviction is affirmed. The U.S. Supreme Court denies certiorari.

Thereafter, David seeks habeas corpus in federal district court. He argues that (1) his
conviction is invalid based on Sanchez and (2) that even without Sanchez, the original ruling that
his
case fell within Quarles was wrong.

For all students:

(1) May David benefit from Sanchez in his federal habeas corpus petition? Why or why
not?
(2) What if Sanchez were decided in January 2022, after the Minnesota Supreme Court
ruled? Does that change your analysis?

(3) Return to the hypo from last class where crime was completed, and David was
sentenced to death as the triggerman. Although David was tried as an adult, he was
only 16 years old at the time of the offense. Assume that after David’s conviction
and sentence are affirmed on appeal, the Supreme Court decides Roper v. Simmons,
which holds that it is unconstitutional to impose capital punishment for a crime
committed while a person is under the age of 18. May David rely on Roper to
overturn his capital sentence when he seeks federal habeas review? Why or why not?