## Facts

- C. J. Griffin was convicted in an Alabama trial court of assault with intent to ravish and sentenced to 20 years’ imprisonment.
- Griffin later alleged he was not represented by counsel at trial, was nearly illiterate, and lacked funds to hire an attorney.
- The criminal court minutes recited that Griffin was represented by counsel at trial.
- Griffin filed a state habeas corpus petition in the Circuit Court of Montgomery County against the Kilby Prison warden, seeking to present evidence contradicting the minutes.
- The circuit court refused to receive extrinsic evidence to contradict the trial record, granted the State’s motion to strike the petition, and ordered Griffin returned to custody.
- Griffin appealed the denial of habeas relief to the Supreme Court of Alabama.

## Issues

1. Whether, in a habeas corpus proceeding, a prisoner may introduce extrinsic evidence to contradict a facially regular criminal court record stating that the defendant was represented by counsel.
2. Whether habeas corpus may be used to attack a conviction based on an asserted defect that does not appear on the face of the record.

## Decision

- The Supreme Court of Alabama affirmed the denial of habeas relief.
- The court held that habeas corpus is a collateral remedy limited to defects apparent on the face of the proceedings, including lack of jurisdiction.
- Because the record was regular on its face and recited representation by counsel, Griffin could not use habeas to impeach that record with parol (extrinsic) evidence.
- The court indicated that claims dependent on facts outside the record must be pursued, if at all, through direct review or a writ of error coram nobis.

## Legal Principles

- State habeas corpus is a collateral attack and generally reaches only jurisdictional defects or other invalidities apparent on the face of the proceedings.
- When the criminal court record is regular on its face and shows jurisdiction, habeas courts will not permit extrinsic evidence to contradict the record’s recitals.
- Off-record claims (including assertions that counsel was absent despite a contrary record recital) are not cognizable in habeas and must be raised through other procedural vehicles such as coram nobis or direct appellate review.

## Conclusion

The Alabama Supreme Court upheld the striking of Griffin’s habeas petition, ruling that habeas corpus cannot be used to contradict a facially valid trial record reciting counsel’s presence; challenges dependent on facts outside the record must be brought through other postconviction or appellate procedures.


Griffin v. State, 63 So. 2d 682 (Ala. 1953)