Rose v. Lundy

After his rape and crime-against-nature convictions were affirmed on direct appeal and post-conviction relief was denied in Tennessee courts, Noah Lundy (defendant, on habeas as petitioner) filed a federal habeas petition under 28 U.S.C. § 2254 raising two claims that had been exhausted in state court and two that had not. The district court granted the writ despite the unexhausted claims, saying they could be considered "collaterally," and the Sixth Circuit affirmed; the state (plaintiff, on appeal as Rose) sought Supreme Court review of how mixed petitions should be handled.