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appealhabeas corpuswill
statuteappealtrialhabeas corpuswillrespondentjury trial

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Rose v. Lundy, 455 U.S. 509, 102 S.Ct. 1198, 71 L.Ed.2d 379

Facts

Noah Lundy was convicted of rape and other charges in a Tennessee state court. After his convictions were affirmed, he sought post-conviction relief in state court but was unsuccessful. Lundy then filed a federal habeas corpus petition under 28 U.S.C. § 2254, alleging four grounds for relief, two of which were unexhausted. The District Court granted the writ despite the mixed nature of the claims, leading to an appeal.

Following a jury trial, respondent Noah Lundy was convicted on charges of rape and crime against nature, and sentenced to the Tennessee State Penitentiary.

Issue

Whether a federal district court must dismiss a habeas corpus petition containing both exhausted and unexhausted claims.

The important issue before the Court in this case is whether the conservative 'total exhaustion' rule espoused now by two Courts of Appeals, the Fifth and the Ninth Circuits, see ante, at 1201, n. 5, is required by 28 U.S.C. §§ 2254(b) and (c), or whether the approach adopted by eight other Courts of Appeals—that a district court may review the exhausted claims of a mixed petition—is the proper interpretation of the statute.

Rule

Under 28 U.S.C. §§ 2254(b) and (c), a state prisoner's application for a writ of habeas corpus will not be granted unless the applicant has exhausted the remedies available in state courts.

Title 28 U.S.C. §§ 2254(b) and (c) provide that a state prisoner's application for a writ of habeas corpus in a federal district court based on an alleged federal constitutional violation will not be granted unless the applicant has exhausted the remedies available in the state courts.

Analysis

The Supreme Court reasoned that the exhaustion rule serves to promote comity between state and federal courts, allowing state courts the first opportunity to address constitutional violations. The Court concluded that a mixed petition containing both exhausted and unexhausted claims must be dismissed, as it complicates the federal review process and undermines the exhaustion requirement.

Because a rule requiring exhaustion of all claims furthers the purposes underlying the habeas statute, we hold that a district court must dismiss such 'mixed petitions,' leaving the prisoner with the choice of returning to state court to exhaust his claims or of amending or resubmitting the habeas petition to present only exhausted claims to the district court.

Conclusion

The Supreme Court reversed the judgment of the Court of Appeals and remanded the case to the district court for proceedings consistent with its opinion, emphasizing the necessity of dismissing mixed petitions.

Held: The judgment is reversed and the case is remanded.

Who won?

The prevailing party was the state, as the Supreme Court ruled in favor of dismissing the mixed habeas petition, reinforcing the exhaustion requirement.

The petitioner urges this Court to apply a 'total exhaustion' rule requiring district courts to dismiss every habeas corpus petition that contains both exhausted and unexhausted claims.

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