Cage v. Louisiana
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Cage's holding that its particular reasonable doubt instruction was unconstitutional remains. Later courts restricted use of the Cage rule on collateral review. All 68 flagged citations have been read; the 5 confirmed treatments are listed below.
68 later cases cite Cage v. Louisiana; 68 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 Cage v. Louisiana?
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
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The Supreme Court disapproved Cage's wording for reviewing jury instructions and reaffirmed the reasonable likelihood standard from Boyde v. California.
Estelle v. McGuire · Supreme Court of the United States · filed
So that we may once again speak with one voice on this issue, we now disapprove the standard of review language in Cage and Yates, and reaffirm the standard set out in Boyde.
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Limited
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The Fifth Circuit held that Cage could not provide habeas relief under AEDPA to a prisoner whose conviction became final before Cage was decided.
Muhleisen v. Ieyoub · Fifth Circuit · filed
We cannot say that this has occurred. The Supreme Court handed down Cage v. Louisiana, 498 U.S. 39 (1990), upon which petitioner relies, a little over thirteen years after petitioner’s conviction became final.1 That was the first, and so far the only, time the Supreme Court has held a definition of reasonable doubt to have violated the Due Process Clause. See Victor v. Nebraska, 511 U.S. 1, 5 (1994). We are therefore bound by AEDPA to deny Muhleisen’s petition for a writ of habeas corpus.2
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The Louisiana Supreme Court applied its rule that Cage does not reach convictions already final on collateral review and reinstated the challenged convictions.
State v. Penns · Supreme Court of Louisiana · filed
Unless and until the United States Supreme Court resolves the status of a Cage/Humphrey instruction after Victor, our decisions in Smith and Williams, as well as our decision in State ex rel. Taylor v. Whitley, 606 So.2d 1292 (La.1992) (Cage not retroactively applicable to final convictions subject only to collateral attack), and not the decision in Humphrey, bind the district courts of this state in reviewing claims that trial judges have read erroneous instructions on reasonable doubt.
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The Fifth Circuit held that AEDPA barred the prisoner from invoking Cage on habeas review of a conviction that became final before Cage.
Williams v. Cain · Fifth Circuit · filed
We conclude that based on Muhleisen, the district court’s ultimate conclusion–that AEDPA precludes Williams from availing himself on habeas of the rule announced by Cage and later cases–is correct.
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The Supreme Court held that its Cage rule had not been made retroactive for second or successive federal habeas petitions under AEDPA.
Tyler v. Cain · Supreme Court of the United States · filed
Because “made” means “held” for purposes of § 2244(b)(2)(A), it is clear that the Cage rule has not been “made retroactive to cases on collateral review by the Supreme Court.”
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