Townsend v. Sain (1962)
- Docket
- 8
- Decided
- 1962-01-01
- Category
- General
Summary
Question: Is a Federal court required to hold an evidentiary hearing to determine issues of fact in order to rule on the writ of habeas corpus? Conclusion: Yes, when the facts are in dispute and the petitioner did not receive a full and fair evidentiary hearing in state court. In a 5-4 decision, Justice Earl Warren wrote for the majority. At the state level, several crucial facts, such as whether or not the medicine given to Townsend was a "truth serum," were not determined. The record did not provide sufficient information to make an accurate determination. The Supreme Court reversed and remanded to the District Court for an evidentiary hearing. The Supreme Court was careful to note that it did not rule on the truth of the allegations in the petition for writ of habeas corpus. Justice Potter Stewart wrote a dissent, stating that the District Court had made sufficient factual determinations and a new hearing was unnecessary. Justice Tom C. Clark, Justice John M. Harlan, and Justice Byron R. White joined in the dissent.