## Facts

- Joseph Wood, a Black U.S. citizen, was indicted by a New York grand jury, convicted of first-degree murder by a petit jury, and sentenced to death.
- Wood alleged that persons of African descent were excluded from both the grand jury and the petit jury in the jury-selection process.
- New York law did not, on its face, exclude persons of African descent from jury service.
- Wood’s conviction was affirmed by the New York Court of Appeals.
- Wood petitioned for federal habeas corpus in the U.S. Circuit Court for the Southern District of New York, challenging his custody based on alleged discriminatory jury selection.
- The circuit court denied the writ, and Wood appealed to the U.S. Supreme Court.

## Issues

1. Whether a federal court may grant habeas relief from a state conviction based on alleged racial exclusion from juries when state law does not mandate exclusion and the defendant did not timely raise and pursue the claim in state court.
2. Whether federal habeas corpus in a lower federal court may function as a substitute for available state procedures and state appellate review to litigate jury-discrimination objections after conviction.

## Decision

- The Supreme Court affirmed the denial of the writ of habeas corpus.
- The Court held that when state statutes do not exclude persons of African descent from juries, objections alleging discriminatory exclusion must be made in the state trial court at the proper time and pursued through state appellate channels.
- Because Wood did not properly raise and carry that objection through the state system, he could not obtain review of the state court’s adverse outcome through federal habeas corpus in a lower federal court.

## Legal Principles

- Federal habeas corpus is not a substitute for timely objections and ordinary appellate review in state criminal proceedings.
- When a state provides a procedural route to raise federal constitutional objections (including challenges to jury selection), a defendant must present those objections in state court in a timely manner and pursue available state appellate remedies.
- Lower federal courts generally may not use habeas to reopen state convictions on grounds that could have been litigated in state court but were not properly preserved, where the state court had jurisdiction over the person and offense and the judgment is regular on its face.

## Conclusion

The Court limited federal collateral review of state convictions by requiring timely presentation and pursuit of jury-discrimination claims in state courts before seeking federal habeas relief, and it rejected habeas as a vehicle to relitigate claims not properly raised in the state process.


In re Wood, 140 U.S. 278 (1891)