O'Sullivan v. Boerckel

Boerckel (defendant) was convicted of rape, burglary, and aggravated battery and sentenced to serve 20 to 60 years in prison. Boerckel appealed to the Illinois appellate court, claiming that: (1) his confession should have been suppressed because it was the fruit of an unlawful arrest, (2) his confession should have been suppressed because it was coerced, (3) he had not waived his Miranda rights, (4) the prosecutor committed misconduct, (5) he had been denied exculpatory material, and (6) the evidence was insufficient to support a conviction. The appellate court rejected these claims. Next, he filed a petition to the Illinois Supreme Court. However, Boerckel only raised the first, fourth, and fifth claims above. The Illinois Supreme Court denied his petition. The United States Supreme Court denied certiorari. Later, Boerckel filed a petition for writ of habeas corpus in the federal district court. Boerckel was appointed counsel and requested relief on the same grounds as the initial appellate claim except for the accusation of prosecutorial misconduct, which was replaced by an ineffective-assistance-of-counsel claim. The district court held that the three claims that were not included in the petition to the Illinois Supreme Court were procedurally defaulted (that is, that he had not waived his Miranda rights, that his confession was not voluntary, and that the evidence was insufficient to support a conviction). The court of appeals reversed. The United States Supreme Court granted certiorari.