Engle v. Isaac (1981)
- Docket
- 80-1430
- Decided
- 1981-01-01
Summary
Question: Can the respondents claim they are entitled to federal writs of habeas corpus where the Ohio courts refused to allow them to challenge Ohio state jury instructions after the fact? Conclusion: No. Justice Sandra Day O’Connor, writing for a 7-2 majority, ruled in favor of Engle and stated that the respondents cannot challenge the constitutionality of the Ohio jury instructions in federal habeas corpus proceedings. The Court held that the respondents forfeited their right to object to the jury instructions when they did not comply with the Ohio Criminal Code that specified they must make any objections at the time of the trial. The Court also found that the jury instructions themselves were not unconstitutional, as they depend on how a state defines the elements of a particular crime. The jury instructions were consistent with the Ohio state laws regarding to what extent the prosecution must disprove certain affirmative defenses. Thus, the respondents did not have constitutional grounds for the writ. In an opinion concurring in part and dissenting in part, Justice John Paul Stevens agreed with the judgment of the Court that the petition for the writs should be dismissed. However, he argued that such an error in jury instructions would not have resulted in a grave miscarriage of justice. In his dissenting opinion, Justice William J. Brennan, Jr. found that the Court’s dismissal of Isaac’s petition on procedural grounds is illogical, given that Isaac’s claim did not exist when he could have raised the appropriate objection at trial. He also found that the double-pronged standard of cause and prejudice that the Court uses to determine if there are grounds for a habeas claim is too high for any defendant to reasonably meet. He was joined in the dissent by Justice Thurgood Marshall.