Cardinale v. Louisiana
Citation and Court
394 U.S. 437 (1969) — Supreme Court of the United States
Facts
Cardinale was convicted in Louisiana state court. He sought Supreme Court review, raising a federal constitutional claim. The Louisiana courts had not expressly addressed the federal question he now pressed; the state courts had ruled on other grounds.
Issue
Whether the Supreme Court has appellate jurisdiction to review a state court judgment when the federal question was not raised and decided below.
Holding
No. The Supreme Court lacks jurisdiction to review a state court decision on a federal question that was not raised and passed upon in the state courts.
Rule / Doctrine
For the Supreme Court to exercise appellate jurisdiction over a state court judgment, the federal question must have been (1) raised in and (2) decided by the state court. A federal claim appearing for the first time on certiorari does not give the Court jurisdiction.
Significance
Cardinale enforces the requirement that federal questions be properly presented in state court before the Supreme Court may review them, reinforcing the principle that state courts must have a fair opportunity to pass on federal issues. It is paired with the adequate and independent state ground doctrine (Fox Film Corp. v. Muller) in defining the outer limits of Supreme Court appellate jurisdiction over state courts.