Mayle v. Felix
Supreme Court of the United States
April 19, 2005, Argued ; June 23, 2005, Decided
[*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." 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. Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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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
DENEICE A. MAYLE, WARDEN, Petitioner v. JACOBY LEE FELIX
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)
Prior History: ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT.
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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Civil Procedure, Pleadings, Complaints, Requirements for Complaint, Criminal Law & Procedure, Habeas Corpus, Procedure, Court Rules, Pleading & Practice, Rule Application & Interpretation, General Overview, Amendment of Pleadings, Order & Timing of Petitions, Filing of Petitions, Pleadings, Relation Back, Statute of Limitations, Antiterrorism & Effective Death Penalty Act, Crimes Against Persons, Carjacking, Penalties, Trials, Examination of Witnesses, Transmitted & Videotaped Testimony, Time Limitations, Governments, Legislation, Time Limitations, Postconviction Proceedings, Motions to Vacate Judgment, Leave of Court, Pretrial Dismissals, Constitutional Law, Fundamental Rights, Procedural Due Process, Self-Incrimination Privilege, Interrogation, Miranda Rights, Commencement of Criminal Proceedings, Voluntariness, Accrual Period, Judicial Officers, Judges, Evidence, Documentary Evidence, Transcripts & Translations, Criminal Process, Assistance of Counsel