Beard v. Kindler

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Beard v. Kindler
Seal of the United States Supreme Court.svg
Argued November 2, 2009
Decided December 8, 2009
Full case name Jeffrey A. Beard, Secretary, Pennsylvania Department of Corrections, et al., Petitioners v. Joseph J. Kindler
Docket nos. 08-992
Citations 558 U.S. 53 (more)
A state procedural rule that is enforced by the state courts cannot be reviewed in federal court.
Court membership
Case opinions
Majority Roberts, joined by Stevens, Scalia, Kennedy, Thomas, Ginsburg, Breyer, Sotomayor
Concurrence Kennedy, joined by Thomas
Alito took no part in the consideration or decision of the case.

Beard v. Kindler, 558 U.S. 53 (2009), is a United States Supreme Court case that deals with the federal review of state laws, known as the adequate and independent state ground doctrine.


Joseph Kindler was convicted of murder in the state of Pennsylvania, and the jury recommended death. Kindler then challenged his conviction and sentence, but before the trial court could consider his motions Kindler escaped and fled to Canada. The court in Pennsylvania dismissed his post-verdict motions because of his flight. Canadian authorities ultimately captured Kindler, but pending his extradition to the United States he escaped again, evading capture for more than two years. Eventually, however, he was captured and extradited to the United States after his extradition was held to be valid in Kindler v Canada (Minister of Justice).

Upon his return, Kindler attempted to reinstate his post-verdict motions. The trial court denied these requests, citing Pennsylvania fugitive forfeiture laws. Kindler appealed to the Pennsylvania Supreme Court, arguing that the trial court had erred in not considering the merits of the motions. The Pennsylvania Supreme Court denied his motion. Kindler then requested federal habeas corpus relief and the District Court granted it, determining that the state fugitive forfeiture law did not provide adequate basis to bar federal review.

The United States Court of Appeals for the Third Circuit affirmed, and Pennsylvania petitioned the Supreme Court for certiorari. The Commonwealth argued that Kindler could not seek habeas relief in federal court because a federal court cannot review a state court's interpretation of wholly state law.

Opinion of the Court[edit]

The Court ruled in favor of Pennsylvania, with Chief Justice Roberts delivering the opinion of the court. Under the adequate and independent state ground doctrine the Supreme Court cannot, as a general rule, review a state court's interpretation of state law. The law in question was not mandatory; the state courts had discretion in using it. Thus the federal courts erred in allowing Kindler to seek relief in federal court, because the final determination rested with the Supreme Court of Pennsylvania.