William Henry Sawtelle

In this case, Thomas J. Mooney petitioned for a writ of habeas corpus in federal district court, alleging that his state conviction and life sentence for murder violated the Fourteenth Amendment's due process clause because prosecutors knowingly presented perjured testimony at trial, which he could not effectively challenge until after his state appeals were exhausted. The district court denied the petition, finding that Mooney had not exhausted his state remedies and that the petition failed to state a basis for relief. On application for a certificate of probable cause to appeal that denial, the circuit judge reviewed the record and prior state proceedings, including Mooney's unsuccessful coram nobis petition and the U.S. Supreme Court's denial of certiorari, and concluded that the state courts had jurisdiction, had adequately addressed the due process claims, and that habeas corpus could not be used to relitigate those issues or review the state judgment. The application for the certificate was therefore denied.

criminal lawprocedurecivil rights

This bankruptcy case concerned the priority of claims by holders of 'royalty interests' in an oil well operated by the bankrupt lessee, who had sold percentages of gross proceeds from oil production under state-approved assignments. The district court, affirming the referee, subordinated those claims to those of general creditors. The circuit court held that the assignments transferred only rights to a share of sale proceeds, not title to the oil itself or any trust interest, and created no partnership or superior creditor status. As a result, the holders were deemed claimants to the estate's residuum after general creditors were paid, with their rights junior in priority. The court affirmed the order without addressing certain alternative contentions about specific wells.

business & regulatoryproperty

This case concerned the validity of three oil leases issued in 1921 and 1922 to Pan-American Petroleum Co. covering acreage in Naval Petroleum Reserve No. 1 in Kern County, California, which the United States challenged as fraudulent, the product of conspiracy, and issued without legal authority under statutes governing public lands and naval reserves. Building on a prior related suit that canceled other leases involving the same underlying scandal, the Ninth Circuit reversed the district court's judgment upholding the leases. The court held that the prior litigation did not bar the claims because each lease was a distinct transaction and cause of action not encompassed by the congressional resolution limiting the first suit, that the leases were independently tainted by the same fraud involving Secretary Fall and others, and that defenses such as estoppel or failure to do equity lacked merit. It directed the district court to enter a decree canceling the leases and restoring the lands to the government.

business & regulatoryfederal powerproperty