Howell v. Mississippi
United States Supreme Court
543 U.S. 440, 125 S. Ct. 856, 160 L. Ed. 2d 873 (2005)
Marlon Howell (defendant) was charged with capital murder. At trial, Howell sought to present jury instructions on manslaughter and simple murder, lesser included offenses to capital murder. The trial court denied Howell’s request. Howell was found guilty of capital murder and sentenced to death. Howell appealed his conviction to the Mississippi Supreme Court, arguing that the trial court violated his rights by refusing to present jury instructions at his capital-murder trial about the lesser included offenses. In his brief to the Mississippi Supreme Court, Howell did not specify that he was seeking to vindicate his rights under the Eighth and Fourteenth Amendments to the United States Constitution, cite a specific case that relied on the constitutional provisions, or label his claim as a federal one. Instead, Howell cited a state case that cited a state case that cited a federal case that turned on a relevant constitutional question. The Mississippi Supreme Court upheld Howell’s conviction without addressing his constitutional claim. Howell appealed, and the United States Supreme Court granted certiorari. Mississippi (plaintiff) opposed the appeal, claiming that Howell had failed to properly raise his constitutional claim before the Mississippi Supreme Court.
Rule of Law
Holding and Reasoning (Per curiam)
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