| Townsend v. Sain | |
|---|---|
 | |
| Argued February 19, 1962 Decided March 18, 1963 | |
| Full case name | Townsend v. Sain, Sheriff, et al. |
| Citations | 372 U.S. 293 (more) 83 S. Ct. 745; 9 L. Ed. 2d 770; 1963 U.S. LEXIS 1941 |
| Holding | |
| A federal district court is required to hold an evidentiary hearing to determine the facts on a petition for writ of habeas corpus brought on a constitutional question unless the state court which previously considered the question resolved any factual dispute in a full and fair hearing supported by the record. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Warren, joined by Douglas, Black, Brennan |
| Concurrence | Goldberg |
| Dissent | Stewart, joined by Clark, Harlan, White |
Overruled by | |
| Keeney v. Tamayo-Reyes[1] | |
Townsend v. Sain, 372 U.S. 293 (1963), was a United States Supreme Court case wherein the Court expanded the circumstances in which federal courts should hold evidentiary hearings when presented with petitions for habeas corpus by state prisoners following denial of postconviction relief in state court. The Court held that federal district courts must hold evidentiary hearings if the state court did not resolve all material factual disputes in a full and fair hearing supported by the record.
The case centered around Charles Townsend, who was convicted of a series of murders and robberies and sentenced to death. The issue heard in the Supreme Court centered around a confession Townsend had given while under the influence of an alleged "truth serum". Townsend's attorneys argued that the effects of the truth serum had made the confession inadmissible. Townsend appealed the case by filing a writ of habeas corpus against Sheriff Frank G. Sain of Cook County, Illinois. The case made it to Illinois Supreme Court once, and the Supreme Court twice: first in 1959 and again in 1963. The appeals case however did not revolve around the truth serum, but instead procedural questions surrounding a prisoner's right to an evidentiary hearing during the appeal process.
The court held that Townsend's writ of habeas corpus should not have been summarily denied, and that the lower court should have held an evidentiary hearing to determine the veracity of Townsend's claims. The court repeated its previous decision that coerced confessions were inadmissible, and theorized that a confession via truth serum would thus be inadmissible; the court was careful to avoid saying whether or not Townsend had actually been given a truth serum.
Alongside Fay v. Noia and Sanders v. United States, Townsend is cited as revolutionizing and greatly expanding the use of habeas corpus, leading to it being used as a general purpose appeals tool. However a variety of Supreme Court decisions since then have narrowed its application.[2]