Estelle, Corrections Director v. Dorrough

Summary

The Court held that Texas's statute automatically dismissing the pending appeal of an escaped felony defendant, subject to limited reinstatement provisions, does not violate the Equal Protection Clause. Both challenged classifications were rationally related to permissible interests in deterring escape, encouraging surrender, and preserving orderly appellate procedure. The Court therefore reversed the Fifth Circuit's order requiring Texas to provide a direct appeal or new trial. Justice Stewart, joined by Justices Brennan and Marshall, dissenting, would have affirmed because the statute imposed irrational consequences on defendants whose appeals were dismissed after recapture.