362
Blackmun, J., dissenting
oner claiming statutory violations, habeas courts serve less to guarantee uniformity of federal law or to satisfy a threshold need for a federal forum than to provide a backstop to catch and correct certain nonconstitutional errors that evaded the trial and appellate courts.4 Thus, this Court has determined that "where the trial or appellate court has had a 'say' on a federal prisoner's claim, it may be open to the § 2255 court to determine that . . . 'the prisoner is entitled to no relief.' " Kaufman v. United States, 394 U. S. 217, 227, n. 8 (1969) (citation omitted). Under Hill and Timmreck, relief may be limited to the correction of "fundamental defect[s]" or "omission[s] inconsistent with the rudimentary demands of fair procedure." Hill, 368 U. S., at 428. The Hill principle, in short, is that where the error is not egregious, the habeas court need not cover the ground already covered by other federal courts.
For the state prisoner, by contrast, a primary purpose of § 2254 is to provide a federal forum to review a state prisoner's claimed violations of federal law, claims that were, of necessity, addressed to the state courts. See Brown v. Allen, 344 U. S. 443, 508 (1953) (opinion of Frankfurter, J.) (§ 2254 collateral review is necessary to permit a federal court to have the "last say" with respect to questions of federal law); Vasquez v. Hillery, 474 U. S. 254 (1986) (requiring exhaustion of federal claims in state courts). Thus, § 2254 motions anticipate that the federal court will undertake an independent review of the work of the state courts, even where the federal claim was fully and fairly litigated. Wright v. West, 505 U. S. 277 (1992) (O'Connor, J., concurring in judgment) (affirming that a state court's determina-4 In fact, § 2255 requires a prisoner to file his motion in the court that imposed his sentence as a further step in his criminal case, not as a separate civil action. Advisory Committee's Note on Habeas Corpus Rule 1, 28 U. S. C., p. 416 (governing § 2255 proceedings).
Page: Index Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 NextLast modified: October 4, 2007