Mooney v. Holohan, 294 U.S. 103 (1935)

Mooney v. Holohan clarified the requirements of due process of law under the Fourteenth Amendment and held that exhaustion of state remedies was required before an inmate in state prison could file a petition for writ of habeas corpus in federal court. Mooney was convicted of murder and originally sentenced to death, but his sentence was later commuted to life imprisonment.

Mooney charged that he was denied due process of law by the prosecution’s knowingly using perjured testimony to obtain his conviction and suppressing evidence that would have impeached that false testimony. In response, the attorney general of California stated that proper notice and hearing were all that was necessary to satisfy the requisites of due process of law. After discussing the importance of due process as a fundamental concept of justice, the Court held that it could not be satisfied by mere notice and hearing if a state deprived a defendant of liberty by deliberately deceiving the court and jury.

The Court declared that a state must afford corrective judicial process to remedy wrongs flowing from the denial of due process of law. Mooney, however, had never applied for a writ of habeas corpus on the grounds he asserted to the Supreme Court. Therefore, a remedy was still available in California, and Mooney was required to exhaust his remedies there.

Mooney emphasized the importance of due process of law and the role of the state in safeguarding it, and also instructed inmates that exhaustion of state remedies was required for writs of habeas corpus.

EARL F. MARTIN

See also Due Process; Habeas Corpus: Modern History