Jennings v. Stephens (2014)
- Docket
- 13-7211
- Decided
- 2014-01-01
Summary
Question: Did the U.S. Court of Appeals for the Fifth Circuit err in holding that that a federal habeas petitioner who prevailed in district court must file a separate certificate of appealability to respond to the state's appeal? Conclusion: Yes. Justice Antonin Scalia delivered the opinion for the 6-3 majority. The Court held that, when an appellee does not cross-appeal, he may urge a defense of his judgment on alternative grounds without filing a certificate of appealability unless doing so would enlarge his rights or lessen those of his adversary as provided by the previous judgment. In this case, allowing Jennings to urge a defense of his judgment did not materially affect either his rights or those of the state. The Court held that this rule provides sufficient procedural safeguards to prevent a proliferation of frivolous habeas claims. Additionally, the statutory language that created the certificate of appealability requirement only dealt with the taking of appeals, not with a defense of a judgment from which an appeal has already been taken. Therefore, that requirement was not relevant in cases such as this one. Justice Clarence Thomas wrote a dissent in which he argued that Jennings' argument in defense of a previous judgment constituted a cross-appeal because it altered the grounds on which he could obtain relief. Because the argument was essentially a cross-appeal, a certificate of appealability should be required. Adhering to this standard rule not only aligns with previous habeas corpus jurisprudence but also prevents a rise in the number of frivolous appeals. Justice Anthony M. Kennedy and Justice Samuel A. Alito, Jr. joined in the dissent.