Spanier v. Dir. Dauphin Cty. Prob. Servs.

In Spanier v. Dir. Dauphin Cty. Prob. Servs., Spanier, the former Penn State president, challenged his state-court conviction through a petition for a writ of habeas corpus, arguing that his rights under the Due Process and Ex Post Facto Clauses were violated. He also argued that his due process rights were violated by the application of an exception to the statute of limitations. The District Court granted Spanier’s petition and vacated his conviction. The 3rd Circuit vacated the District Court’s order and reinstated the conviction. The 3rd Circuit first noted that Spanier’s allegation — that the state court unforeseeably applied a law retroactively — is a due process issue, not an ex post facto issue. After a meticulous and thorough analysis of the habeas standard as well as the caselaw, the 3rd Circuit held that there was no due process error. Under clearly established federal law, state courts have considerable latitude to rule on the meaning of statutes, and this latitude extends to announcing a new rule of law to uphold a conviction—so long as the new rule is not unexpected and indefensible. Moreover, Spanier’s statute of limitations argument was not a basis for relief because he did not show that the Superior Court’s reasoning contradicted clearly established federal law.

Spanier