Beard v. Kindler 588 U.S. ____ (2009) is a United States Supreme Court case that deals with the federal review of state laws, known as the adequate and independent state ground

Adequate and independent state ground

The adequate and independent state ground doctrine is a doctrine of United States law governing the power of the U.S. Supreme Court to review judgments entered by state courts.- Introduction :...

doctrine.

Background

Kindler was convicted of murder in the state of Pennsylvania and the jury recommended death. Kinder then challenged his conviction and sentence, but before the trial court could consider his motions Kindler escaped and fled to Canada. The court in Pennsylvania dismissed his post-verdict motions because of his flight. Canadian authorities ultimately captured Kinder, but pending his extradition to the United States he escaped again, evading capture for more than two years. Eventually, however, he was captured and extradited to the United States. Upon his return, Kinder attempted to reinstate his post-verdict motions. The trial court denied these requests citing Pennsylvania fugitive forfeiture laws. Kinder appealed to the Pennsylvania Supreme Court that the trial court had erred in not considering the merits of the motions. The Pennsylvania Supreme Court denied his motion. Kindler then requested federal habeas relief and the District court granted it determining that the state fugitive forfeiture law did not provide adequate basis to bar federal review. The Third Court of Appeals affirmed and Pennsylvania petitioned the Supreme Court for certiorari. The Commonwealth argued that Kindler could not seek habeas relief in federal court because federal court cannon review wholly state laws on state grounds.

Decision of the Court

The Court ruled in favor of Pennsylvania with Chief Justice Roberts delivering the opinion of the court. Under the adequate and independent state ground doctrine the Supreme Court cannot, as a general rule, review state laws determined by state courts. The law in question was not a mandatory enforcement, the state courts had discretion in using it. Thus the federal courts erred in allowing Kindler to seek relief in federal court because the final determination rested with the Supreme Court of Pennsylvania.