Patterson v. Alabama

Patterson's case raised issues of technical legal violations taking precedence over what the High Court considered a miscarriage of justice. The Supreme Court essentially claimed that it could intervene in a situation with no obvious legal question but which still involved injustice. In this case, the court would not allow paperwork requirements to put a person's life at risk and violate constitutional rights. Patterson had appealed his conviction on the same basis as Norris, but the state of Alabama argued that the U.S. Supreme Court had no jurisdiction because Patterson failed to raise his claim in a timely manner and file a new-trial motion before the expiration of the state court's term. Because the bill of exception had been stricken by the Alabama Supreme Court, technically Patterson had never appealed and had not exhausted all remedies at the state level.

The U.S. Supreme Court took the unusual step of remanding the case back to the Alabama Supreme Court, asserting that the Alabama judges would not have upheld Patterson's conviction if they had known the outcome of Norris. The federal question over jury makeup that was raised in Patterson was exactly the same one that the Supreme Court had decided in Norris, and both cases deserved an equal amount of scrutiny, regardless of procedural niceties. Chief Justice Hughes, writing for the majority, claimed that the court could not only address errors in legal judgment, but also see that justice was met. Implied in the ruling was the threat that, if the Alabama high court failed to overturn the verdict, the Supreme Court would review it again in the interest of justice. The Alabama Supreme Court reversed the guilty verdicts.

Along with Norris, the Patterson case showed that although the change would be halting and often only a token effort, the South could not return to a system that used all-white juries and expect the federal courts to uphold their decisions. The constitutional prohibition on racial discrimination before the law was on its way to being consistently and strongly enforced. Although this was an important precedent, the overall outcome was not as positive for Haywood Patterson. He was tried a fourth time and again found guilty. In something of a victory, given the circumstances, Patterson managed to avoid the death penalty in 1936 and was sentenced to 75 years in prison. Trapped in one of the worst prison systems in the country with little possibility of parole, he escaped in 1948. Patterson made his way to Michigan, where the governor refused to sign extradition papers to return him to Alabama. Suffering from cancer and in prison on charges of manslaughter, he died in 1952.

Patterson v. Alabama