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Keywords

appealtrialmotionhabeas corpuslease

litigationappealhabeas corpusleaserespondent

Related Cases

Hilton v. Braunskill, 481 U.S. 770, 107 S.Ct. 2113, 95 L.Ed.2d 724, 55 USLW 4672, 7 Fed.R.Serv.3d 1149

Facts

Dana Braunskill, a state prisoner, was convicted of sexual assault and unlawful possession of a weapon in New Jersey and sentenced to eight years in prison. After filing a habeas corpus petition, the Federal District Court found that his constitutional rights had been violated during his trial and ordered that a writ of habeas corpus issue unless the state granted a new trial within 30 days. The state sought to stay this order pending appeal, but the District Court denied the motion, leading to further appeals.

Respondent Dana Braunskill was convicted in the Superior Court of New Jersey, Law Division, of sexual assault and unlawful possession of a weapon, in violation of N.J.Stat.Ann. §§ 2C:14–2, 2C:39–5(d) (West 1982 and Supp.1986–1987), and was sentenced to eight years' imprisonment.

Issue

What factors may federal courts consider when deciding whether to stay a district court order granting relief to a habeas petitioner pending the state's appeal?

We are asked to decide what factors these provisions allow a court to consider in determining whether to release a state prisoner pending appeal of a district court order granting habeas relief.

Rule

Federal Rule of Appellate Procedure 23(c) and (d) create a presumption favoring the release of a successful habeas petitioner pending appeal, but this presumption can be overcome by considering traditional stay factors, including the likelihood of success on the merits, irreparable injury, and public interest.

Federal Rule of Appellate Procedure 23(c) provides that, when the Government appeals a decision granting a writ of habeas corpus, the habeas petitioner shall be released from custody 'unless the court or justice or judge rendering the decision, or the court of appeals or the Supreme Court, or a judge or justice of either court shall otherwise order.'

Analysis

The Supreme Court determined that the lower courts had taken too narrow a view of their discretion under Rules 23(c) and (d). The Court emphasized that federal courts should consider not only the risk of flight but also the potential danger to the community and the state's interest in custody. The Court's analysis highlighted the need for individualized judgments based on the traditional standards for stays of civil judgments.

We think that the District Court and the Court of Appeals, in relying on the latter's decision in Carter v. Rafferty, supra, took too limited a view of the discretion allowed to federal courts under Rules 23(c) and (d) in staying pending appeal an order directing the release of a habeas petitioner.

Conclusion

The Supreme Court vacated the judgment of the Court of Appeals denying the state's application for a stay and remanded the case for further proceedings consistent with its opinion.

We therefore vacate the judgment of the Court of Appeals denying petitioner's application for a stay in this case, and remand the case to that court for further proceedings consistent with this opinion.

Who won?

The Supreme Court, as it vacated the lower court's decision and remanded the case, effectively allowing the state to seek a stay of the habeas petitioner's release pending appeal.

The majority rejects this approach, deferring instead to the State's interest as an adversary party in litigation.

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