Mayle v. Felix

Mayle v. Felix

Supreme Court of the United States

April 19, 2005, Argued ; June 23, 2005, Decided

No. 04-563


 [*648]  [**2566]   Justice Ginsburg delivered the opinion of the Court.

LEdHN[1A][] [1A] This case involves two federal prescriptions: the one-year limitation period imposed on federal habeas corpus petitioners by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. § 2244(d)(1); and the rule that pleading amendments relate back to the filing date of the original pleading when both the original plea and the amendment arise out of the same "conduct, transaction, or occurrence," Fed. Rule Civ. Proc. 15(c)(2).

Jacoby Lee Felix, California prisoner and federal habeas petitioner, was convicted in California state court of first-degree murder and second-degree robbery, and received a life sentence. Within the one-year limitation period AEDPA allows for habeas petitions, Felix filed a pro se petition in federal court. He initially alleged, inter alia, that the admission [****10]  into evidence of videotaped testimony of a witness for the prosecution violated his rights under the Sixth Amendment's Confrontation Clause. Five months after the expiration of AEDPA's time limit, and eight months after the federal court appointed counsel to represent him, Felix filed  [*649]  an amended petition in which he added a new claim for relief: He asserted that, in the course of pretrial interrogation, the police used coercive tactics to obtain damaging statements from him, and that admission of those statements at trial violated his Fifth Amendment right against self-incrimination. The question presented concerns the timeliness of Felix's Fifth Amendment claim.

HN1[] In ordinary civil proceedings, the governing Rule, Rule 8 of the Federal Rules of Civil Procedure, requires only "a short and plain statement of the claim showing that the pleader is entitled to relief." Fed. Rule Civ. Proc. 8(a)(2). Rule 2(c) of the Rules Governing Habeas Corpus Cases requires a more detailed statement. The habeas rule instructs the petitioner to "specify all the grounds for relief available to [him]" and to "state the facts supporting each ground." 1 HN2[] By statute, Congress provided that a habeas petition [****11]  "may be amended . . . as provided in the rules of procedure applicable to civil actions." 28 U.S.C. § 2242. The Civil Rule on amended pleadings, Rule 15 of the Federal Rules of Civil Procedure, instructs: HN3[] "An amendment of a pleading relates back to the date of the original pleading when . . . the claim . . . asserted in the amended pleading arose out of the conduct, transaction, or occurrence set forth or attempted to be set forth in the original pleading." Fed. Rule Civ. Proc. 15(c)(2).

The issue before us is one on which federal appellate courts have divided: Whether, under Federal Rule of Civil Procedure 15(c)(2), Felix's amended petition, filed after AEDPA's one-year limitation and targeting his pretrial statements, relates back to the date [****12]  of his original timely filed petition, which targeted the videotaped witness testimony. Felix urges, and the Court of Appeals held, that the  [*650]  amended petition qualifies for  [***590]  relation back because both the original petition and the amended pleading arose from the same trial and conviction. We reverse the Court of Appeals' judgment in this regard. HN4[] An amended habeas petition, we hold, does not relate back (and thereby escape AEDPA's one-year time limit) when it asserts a new ground for relief supported by facts that differ in both time and type from those the original pleading set forth.

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545 U.S. 644 *; 125 S. Ct. 2562 **; 162 L. Ed. 2d 582 ***; 2005 U.S. LEXIS 5016 ****; 18 Fla. L. Weekly Fed. S 464


Subsequent History:  [****1] On remand at  Felix v. Mayle, 420 F.3d 915, 2005 U.S. App. LEXIS 17518 (9th Cir., Aug. 18, 2005)

US Supreme Court rehearing denied by  Mayle v. Felix, 545 U.S. 1158, 126 S. Ct. 25, 162 L. Ed. 2d 923, 2005 U.S. LEXIS 5334 (U.S., Aug. 22, 2005)


 Felix v. Mayle, 379 F.3d 612, 2004 U.S. App. LEXIS 16348 (9th Cir. Cal., 2004)

Disposition: Reversed and remanded.

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