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Fay v. Noia | 372 U.S. 391 (1963)
A state prisoner never directly appealed his conviction, but he eventually sought habeas corpus relief in federal court. The United States Supreme Court case that followed, Fay versus N oia, featured a dispute about whether the prisoner’s petition was properly dismissed for failure to exhaust state remedies.
Based on their individually signed confessions and no other evidence, Charles Noia, Santo C aminito, and Frank Bonino were convicted of felony murder in New York court for killing someone during a robbery. Caminito and B onino appealed their convictions to the New York Supreme Court, Appellate Division, without success. However, both of them were eventually released after their confessions were found to have been illegally coerced in violation of the Fourteenth Amendment. Noia never directly appealed his own conviction, largely because of comments that the judge made during the sentencing phase of his case. Specifically, the judge indicated that he had seriously considered imposing the death penalty even though the jury’s recommendation was life in prison.
After his two codefendants were released, Noia filed a habeas corpus petition in the federal district court for the Southern District of New York, naming prison warden Edward Fay as the respondent. Noia raised one issue, that his confession had been coerced in violation of the Fourteenth Amendment. Although it was agreed that Noia’s confession had been coerced, the district court dismissed his petition because of his failure to directly appeal his conviction and exhaust his state remedies. The Second Circuit reversed, concluding that Noia didn’t need to exhaust state remedies that were no longer procedurally available when he filed his petition. Alternatively, the Second Circuit reasoned that there were exceptional circumstances excusing Noia’s failure to exhaust his state remedies. Fay appealed to the United States Supreme Court, which granted cert.
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