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Habeas Corpus Grant Reversed, Be Easy on State Courts Says 1st Cir

By Gabriella Khorasanee, JD on January 07, 2014 | Last updated on March 21, 2019

With the huge amount of habeas corpus claims that inundate courts, the First Circuit recently released an opinion that commented on the issue. And, in an interesting turn, instead of criticizing state courts for short, sometimes arguably unclear opinions, the First Circuit instead took issue with federal reviewing courts (yes you, District Court of Massachusetts).

In Hodge v. Mendonsa, the First Circuit had to determine whether the Massachusetts Appeals Court ("MAC") rejected an argument on its merits when the MAC did not expressly discuss the argument by name, and whether a theory is procedurally barred when addressed in a footnote.

Factual and Procedural Background

Ivan Hodge was convicted of second-degree murder, along with his co-defendant O'Neil Francis, and is serving a life sentence. The MAC affirmed his conviction, and the Massachusetts Supreme Judicial Court denied review. Pursuant to 28 U.S.C. § 2254, Hodge filed a habeas corpus claim, which the district court granted.

Issue Adjudication and Procedural Bar

On appeal, the First Circuit held that even though the MAC did not use the Chambers case name in addressing an argument, the fact that the MAC substantively addressed the claim, as well as cited to another case the relied on Chambers was sufficient. Furthermore, the court rejected Hodge's procedural bar argument because "a procedural bar ruling must stand in all but exceptional circumstances," and because such circumstances did not exist here, Hodge's claim failed.

To us, this case is more interesting for what it doesn't say, than what it does. While reading the case, we were sure the MAC would get a benchslap for not being as clear as it could have been in writing its opinion. Instead, the First Circuit gave a benchslap to the district court reminding the court of the Supreme Court's statement that "[F]ederal courts have no authority to impose mandatory opinion-writing standards on state courts."

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