Case law · Highest court · Federal

Thomas v. Arn

Decided
January 27, 1986
Docket
84-5630
Status
Published
Jurisdiction
Federal

Cited 28,671 timesSuperseded by statute (not yet verified)Possible negative treatment: superseded by statute (not yet verified) · Crocs, Inc. v. Joybees, Inc.

What later courts said

Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.

How the opinion begins

Justice Marshall delivered the opinion of the Court.

In 1976, Congress amended §101 of the Federal Magistrates Act, 28 U. S. C. § 636, to provide that a United States district judge may refer dispositive pretrial motions, and petitions for writ of habeas corpus, to a magistrate, who shall conduct appropriate proceedings and recommend dispo [*142] sitions. Pub. L. 94-577, 90 Stat. 2729.[1] The amendments also provide that any party that disagrees with the magistrate’s recommendations "may serve and file written objections” to the magistrate’s report, and thus obtain de novo review by the district judge.[2] The question presented is whether a court of appeals may exercise its supervisory powers to establish a rule that the failure to file objections to the magistrate’s report waives the right to appeal the district court’s judgment. We hold that it may. b-i Petitioner was convicted by an Ohio court m 1978 of fatally shooting her common-law husband during an argument. [*143] The evidence at trial showed that the victim was a violent man who had beaten petitioner on a number of occasions during the previous three years. Petitioner raised the issue of self-defense at trial, and sought to call two witnesses who would present expert testimony concerning the Battered Wife Syndrome. After conducting a voir dire of these witnesses in chambers, the trial court refused to admit the testimony, on the grounds that the jury did not need the assistance of expert testimony to understand the case and that the witnesses, who had not personally examined petitioner, could not testify about her state of mind at the time of the shooting.

The Court of Appeals of Cuyahoga County reversed. State v. Thomas, 64 Ohio App. 2d 141, 411 N. E. 2d 845 (1979). The court’s syllabus[3] concluded that testimony concerning the Battered Wife Syndrome is admissible “to afford the jury an understanding of the defendant’s state of mind at the time she committed the homicide.” App. 9. The Ohio Supreme Court, on discretionary review, reversed. State v. Thomas, 66 Ohio St. 2d 518, 423 N. E. 2d 137 (1981). The court held that the testimony was irrelevant to the issue of self-defense, and that its prejudicial effect would outweigh its probative value. Having exhausted state remedies, petitioner sought habeas corpus relief in the United States District Court for the Northern District of Ohio. The petition raised, inter alia, the question whether petitioner was denied a fair trial by the trial court’s refusal to admit testimony concerning the Battered Wife Syndrome. Petitioner filed a memorandum of law in support of the petition. The District Judge, acting pursuant to 28 U. S. C. § 636(b)(1)(B), referred the case, including petitioner’s memorandum of law, to a Magistrate. The Magistrate did not hold a hearing. On May 11, 1982, the Magistrate issued his report, containing proposed findings of fact and conclusions of law and recom [*144] mending that the writ be denied. On the issue of the Battered Wife Syndrome testimony, the Magistrate concluded that the trial court’s failure to admit the proffered testimony had not impaired the fundamental fairness of the trial, and therefore was not an adequate ground for habeas corpus relief.

Statutes cited

Cite this

Thomas v. Arn, 474 U.S. 140 (1986)

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