Monday, April 29, 2013

Allen v. McCurry case brief

Allen v. McCurry case brief
449 U.S. 90 (1980)

CASE SYNOPSIS: The court granted certiorari on a decision from the United States Court of Appeals for the Eighth Circuit, which held that defendant's inability to obtain federal habeas corpus relief upon his Fourth Amendment claim in state court rendered the doctrine of collateral estoppel inapplicable to his suit for redress of constitutional violations under 42 U.S.C.S. § 1983.

FACTS: Defendant was convicted in state court after his motion to suppress evidence on federal constitutional grounds was denied. Because defendant did not assert that the state court had denied him a fair opportunity to litigate his constitutional claims, he was barred from seeking a writ of habeas corpus in federal court. Defendant nonetheless sought relief in federal court by bringing suit under 42 U.S.C.S. § 1983 against the officers who entered his home and seized the evidence used to convict him.
On appeal, the Court held that defendant's suit was his only means of constitutional redress, and that the officers could not assert collateral estoppel as a defense.

The Court concluded that nothing in the language or legislative history of 42 U.S.C.S. § 1983 proved a congressional intent to deny binding effect to a state court judgment, when that court had given the parties a full and fair opportunity to litigate their federal claims. The Court noted that 42 U.S.C.S. § 1983 afforded an opportunity for federal relief for certain types of injuries, and was not intended as a substitute for a federal writ of habeas corpus.

CONCLUSION: The Court reversed the lower appellate court's judgment.

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