Tuesday, November 5, 2013

Herrera v. Collins case brief

Herrera v. Collins case brief summary
506 U.S. 390 (1993)

The United States Court of Appeals for the Fifth Circuit affirmed the denial of petitioner inmate's request for a writ of habeas corpus. The court granted certiorari to review the denial.

Over 10 years after the inmate was convicted of capital murder, he filed a habeas corpus petition arguing that he was actually innocent of the crime. The inmate supported his claim with affidavits collected years after the trial indicating that his brother committed the murder. The inmate argued that his showing of innocence entitled him to federal habeas relief.


  • The court held that the inmate's claim of actual innocence based on newly discovered evidence was not a ground for federal habeas corpus relief absent an independent constitutional violation. 
  • The State met its burden of proving at trial that the inmate was guilty of the capital murder beyond a reasonable doubt. 
  • Thus, the inmate did not come before the courts as one who was "innocent," but as one who had been convicted by due process of law. 
  • Texas' refusal to entertain the inmate's newly discovered evidence eight years after his conviction did not transgress any principle of fundamental fairness.
The judgment denying the inmate's petition for habeas corpus was affirmed.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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