Rose v. Locke

Harold Locke (defendant, on habeas as petitioner) broke into a neighbor's apartment with a butcher knife and forced her to submit to oral sex; he was convicted under Tennessee's sodomy statute. After the Tennessee Court of Criminal Appeals affirmed, Locke sought federal habeas relief against warden Jimmy Rose (plaintiff, on appeal as petitioner), arguing the statute's "crimes against nature" language didn't give fair notice it covered oral sex. The district court denied the petition, but the court of appeals reversed and granted the writ, prompting Supreme Court review.