Mayle v. Felix - 545 U.S. 644, 125 S. Ct. 2562 (2005)

Rule:

An amended habeas petition does not relate back (and thereby escape the Antiterrorism and Effective Death Penalty Act of 1996'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.

Facts:

Within the one-year limitation period under 28 U.S.C.S. § 2244(d)(1) of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), respondent Jacoby Lee Felix, filed his habeas petition, alleging that the admission of videotaped testimony of a witness for the prosecution violated his confrontation rights. Five months after the expiration of AEDPA's time limit, and eight months after counsel was appointed to represent respondent, he filed an amended petition in which he added a new claim, alleging 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 United States Court of Appeals for the Ninth Circuit found that the amended petition qualified for relation back under Fed. R. Civ. P. 15(c)(2). Petitioner warden petitioned for a writ of certiorari, which was granted.

Issue:

Did the amended petition qualify for relation back under Fed. R. Civ. P. 15(c)(2)?

Answer:

No.

Conclusion:

The Supreme Court reversed the judgment of the appellate court to the extent that it allowed relation back, and remanded the case for further proceedings. Under Fed. R. Civ. P. 15(c)(2), the Court determined that the respondent’s amended petition did not relate back to the date of his original timely-filed petition and was thus untimely, because the amended petition asserted a new ground for relief supported by facts that differed in both time and type from those the original petition set forth. The Court rejected the respondent’s argument that same "conduct, transaction, or occurrence" meant same "trial, conviction, or sentence."