State rules blocking appeals
Johnson v. Donna Kay Lee
In brief
The Supreme Court overturned the Ninth Circuit's ruling and returned Lee's case for more proceedings.
- Where it stands
- Decided
Decided · May 31, 2016 · Per curiam
- What it’s about
- Donna Kay Lee’s case concerned whether California could bar claims left out of a direct appeal from being raised later, even though the rule was not used in some cases where it could have applied.
- Who it affects
- The Ninth Circuit's judgment has been overturned, and Lee's case remains open.
Summary: written with AI from the case record.

What it's about
The Supreme Court overturned the Ninth Circuit’s judgment and sent the case back for further proceedings (remanded).
California's rule can block claims left out of an appeal challenging a conviction from being raised in a later challenge.
Question presented
Is evidence that there are times when a procedural bar was not used in cases in which it could have been applied sufficient to show that the bar is not adequate?
What the Court decided
Holding
The judgment of the Court of Appeals for the Ninth Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.
- Result
- Reversed
The vote
- Majority author
- Per Curiam
What's next
The Ninth Circuit must continue the case under the Supreme Court's opinion.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Opinion added: Lee
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.