Case Citator › Townsend v. Sain

Townsend v. Sain

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Supreme Court of the United States
Citation
372 U.S. 293
Decided
Confirmed treatments
3
Flagged citations read
329 of 329
Citing cases (total)
4,485
Treatment dates
1992–2013
Overruled in part
A reviewed court has overruled part of this case’s holding. Townsend v. Sain is overruled in part; the 3 confirmed treatments are listed below. Keeney v. Tamayo-Reyes replaced Townsend's deliberate-bypass rule with cause and prejudice when a prisoner failed to develop the state-court record, and AEDPA's § 2254(e) later superseded the affected pre-AEDPA hearing standard.
More on how this was screened

An unpublished Fifth Circuit opinion also declined to extend Townsend's interrogation-linked coercion rule to remote institutional conditioning. All 329 flagged citations have now been read; later opinions continue to apply Townsend's surviving factfinding and hearing principles while repeatedly reporting the Keeney and statutory changes.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

4,485 later cases cite Townsend v. Sain; 329 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Townsend v. Sain?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in Part

  • The Court overruled Townsend's deliberate-bypass standard for a prisoner's failure to develop material facts in state court and substituted cause and prejudice.

    Keeney v. Tamayo-Reyes · Supreme Court of the United States · filed

    Because the holding of Townsend v. Sain that Fay v. Noia’s deliberate bypass standard is applicable in a case like this had not been reversed, it is quite understandable that the Court of Appeals applied that standard in this case. However, in light of more recent decisions of this Court, Townsend’s holding in this respect must be overruled.
    Read the full opinion on CourtListener →

Superseded by Statute

  • The court held that AEDPA's § 2254(e) superseded Townsend's pre-AEDPA evidentiary-hearing standard where the prisoner failed to develop the state-court record.

    Burris v. Parke · Seventh Circuit · filed

    But, for the reasons that follow, we think that a federal evidentiary hearing is unnecessary even under the standard of Townsend v. Sain, 372 U.S. 293, 83 S.Ct. 745, 9 L.Ed.2d 770 (1963), which Keeney overruled in part and which § 2254(e) supersedes.
    Read the full opinion on CourtListener →

Limited

  • In an unpublished opinion, the court declined to extend Townsend's interrogation-linked coercion rule to remote institutional conditioning that only encouraged confession generally.

    Doyle v. Stephens · Fifth Circuit · filed

    That claim is an impermissible broadening of Townsend and plainly out- side settled law.
    Read the full opinion on CourtListener →

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