Reed v. Farley

Summary

The Court affirmed the denial of federal habeas relief, holding that failure to comply with the Interstate Agreement on Detainers' 120-day trial requirement is not cognizable under § 2254 when the defendant did not object when the trial date was set and suffered no prejudice from the delay. A majority agreed that the fundamental-defect standard governing statutory claims under § 2255 also governs such claims under § 2254, and rejected Reed's Sixth Amendment argument. Justice Ginsburg's three-Justice discussion, joined by Chief Justice Rehnquist and Justice O'Connor, reserved whether habeas relief might be available when a state court disregards a timely demand for compliance. Justice Scalia, joined by Justice Thomas, concurred in part and in the judgment, concluding more broadly that violation of the IAD deadline cannot itself justify habeas relief and suggesting that prior full and fair litigation independently could preclude relief. Justice Blackmun, joined by Justices Stevens, Kennedy, and Souter, dissented, arguing that Congress's mandatory dismissal remedy made the violation sufficiently serious for habeas review and that Reed's written requests adequately invoked his rights.