Hartfield v. Thaler (Original)
Annotate this CasePetitioner was sentenced to death in 1977. The Supreme Court reversed his conviction and ordered a new trial. The State unsuccessfully moved for rehearing. Though the Court's mandate had already issued, the governor commuted Petitioner's death sentence to life. Petitioner filed a pro se application for the writ of habeas corpus, and a year later, applied for the writ of mandamus to compel the new trial. The Supreme Court denied both. Petitioner then filed a petition for the writ of habeas corpus with the United States District Court for the Southern District of Texas; the federal district court reported Petitioner was not in custody under state court judgment because the trial court's judgment of conviction ceased to exist when the Supreme Court issued its mandate and the governor's commutation came too late. However, because Petitioner was confined in the Eastern District, the case was transferred. A magistrate judge in the Eastern District recommended petitioner's application for habeas relief be denied for failing to exhaust a Speedy Trial Clause claim in state court. The district court adopted the Eastern District magistrate's recommendations and dismissed petitioner's habeas application. Petitioner appealed that decision to the Fifth Circuit Court of Appeals. The Fifth Circuit issued an opinion; the State was unsuccessful in moving the federal court for rehearing. Acting on its own motion, the Fifth Circuit withdrew its opinion and certified a question to the Texas Supreme Court asking the Court what was the status of Petitioner's new trial. Upon review, the Supreme Court concluded that the mandate it issued in Petitioner's case reversed the judgment of conviction, and no other court entered any order to alter that reversal. Because some penalty must be assessed for the authority of commutation to be exercised, and Petitioner's death sentence was erased by the Court's mandate, the governor's commutation was a nullity. Therefore the status of Petitioner's judgment of conviction was Petitioner was under no conviction or sentence.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.