## Facts

- Three North Carolina prisoners (Brown, Speller, and Daniels) filed federal habeas corpus petitions challenging their state convictions on federal constitutional grounds, including in a capital case.
- Each petitioner litigated federal claims on direct appeal through the North Carolina Supreme Court.
- Each petitioner sought certiorari from the U.S. Supreme Court on direct review; certiorari was denied.
- After direct review ended, each petitioner filed for federal habeas relief under 28 U.S.C. §§ 2241, 2254 in the U.S. District Court for the Eastern District of North Carolina.
- In Speller and Daniels, the district court held evidentiary hearings and supplemented the record; in Brown, the district court relied on state-court findings without taking new evidence.
- The district court denied relief in all cases, and the Fourth Circuit affirmed.
- The Supreme Court granted certiorari to address important questions about federal habeas review of state convictions and the administration of death sentences.

## Issues

1. Whether § 2254 exhaustion is satisfied when the state’s highest court has adjudicated the federal claims on direct review and the U.S. Supreme Court has denied certiorari, or whether additional state collateral proceedings are required.
2. What effect, if any, a prior Supreme Court denial of certiorari should have on a federal court’s later habeas review of the same conviction.
3. Whether federal habeas courts may reconsider federal constitutional claims already adjudicated in state court, and what weight to give state findings of fact and state-court resolutions of federal issues.
4. When a federal district court must, or may, hold an evidentiary hearing in habeas proceedings.
5. Whether a petitioner’s failure to comply with available state procedures bars federal habeas review absent excusing circumstances.

## Decision

- The Court affirmed the judgments denying habeas relief in all three cases.
- A prisoner exhausts state remedies for § 2254 purposes when the federal claims were decided by the state’s highest court on direct review and certiorari was denied; additional state collateral litigation on the same issues is not required.
- A prior denial of certiorari carries no substantive significance in a later federal habeas proceeding and should be given no weight.
- Federal habeas courts have authority to examine federal constitutional claims even if state courts previously adjudicated them, but may consider and give substantial weight to state proceedings and state factfinding.
- Whether to take new evidence is generally within the district court’s discretion when the state record is available and adequate.
- Failure to use an available state procedure in compliance with state rules can bar habeas review unless the failure is excused by interference or incapacity.
- Any improper consideration by lower federal courts of the earlier certiorari denials was treated as harmless error because it did not affect the outcome.

## Legal Principles

- Exhaustion under 28 U.S.C. § 2254 does not require repetitive state collateral applications when the same federal claims were already presented to and decided by the state’s highest court on direct review.
- A Supreme Court denial of certiorari is not a merits determination and has no evidentiary or preclusive weight in federal habeas review of the same conviction.
- State adjudications do not operate as res judicata on federal constitutional claims in habeas, but federal courts may give significant weight to state-court resolutions, including state factfinding reflected in the record.
- District courts may rely on the state-court record without an evidentiary hearing when the record adequately resolves material factual disputes relevant to the federal claim; hearings are permitted when the record is insufficient.
- A petitioner’s failure to comply with available state procedures may bar federal habeas relief unless the failure resulted from interference or incapacity.

## Conclusion

Brown v. Allen confirmed that federal habeas courts may review constitutional challenges to state convictions after direct state review, clarified that exhaustion is met without redundant state collateral litigation, and instructed that certiorari denials have no merits effect while state findings may be credited and procedural noncompliance may bar relief.


Brown v. Allen, 344 U.S. 443 (1953)