Dretke v. Haley
Haley, an inmate of the Texas Department of Criminal Justice, filed a federal application for writ of habeas corpus, asserting that his conviction of a "state jail felony" (a habitual offender felony, in Haley's case, based on prior theft convictions) was illegal. The state courts had found that Haley was procedurally barred from raising his objections to the sentencing enhancements. Typically, a federal court is barred from providing habeas relief when a state court has denied relief on procedural grounds, except when the petitioner is "actually innocent" of the crime. The district court granted habeas corpus, finding that the prosecution had not sufficiently established that Haley had been convicted of prior felonies and thus Haley was "actually innocent" of committing a "state jail felony." The Fifth Circuit Court of Appeals affirmed, holding in part that the "actual innocence" exception to the procedural default rule applies in noncapital cases that involve habitual felony sentences.
Question Presented:
Whether the "actual innocence" exception to the procedural default rule concerning federal habeas corpus claims should apply to noncapital sentencing error.
