Gonzalez v. Crosby

Supreme Court of the United States · 2005 · Federal Courts

Federal CourtsHabeas CorpusRule 60(b)AEDPARule 60(b)(6)§ 2254§ 2244(b)second or successive petition

Facts

Gonzalez pleaded guilty in Florida state court and later filed a federal habeas petition under § 2254 alleging that his guilty plea was not knowing and voluntary. The District Court dismissed that petition as barred by AEDPA's statute of limitations, concluding that a pending state postconviction motion did not toll the limitations period because it was not "properly filed." After the Supreme Court decided Artuz v. Bennett, Gonzalez filed a pro se Rule 60(b)(6) motion contending that the federal court's statute-of-limitations ruling was incorrect. His motion attacked only the federal court's procedural ruling and did not add any new ground for relief from his conviction.

Issue

Whether, in a § 2254 habeas case, a Rule 60(b) motion is subject to AEDPA's restrictions on second or successive habeas petitions. More specifically, whether a Rule 60(b)(6) motion that challenges only the federal court's prior statute-of-limitations ruling must be treated as a successive habeas application under § 2244(b).

Rule

For purposes of AEDPA, a filing is treated as a second or successive habeas application when it contains a "claim," meaning an asserted federal basis for relief from the state court judgment of conviction. A Rule 60(b) motion presents such a claim if it seeks to add a new ground for relief or attacks the federal court's prior merits resolution of a habeas claim; it is not successive when it attacks only a defect in the integrity of the federal habeas proceedings, such as a prior ruling that precluded a merits determination. Even when not successive, relief under Rule 60(b)(6) requires extraordinary circumstances.

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In Phoenix, Luis Moreno filed a first federal habeas petition under § 2254 challenging his Arizona conviction. The district court dismissed the petition as untimely without reaching any constitutional issue. A year later, Luis filed a Rule 60(b)(6) motion arguing that the district court had misread the tolling statute and therefore wrongly refused to consider the petition on the merits.

How should the district court classify Luis's Rule 60(b)(6) motion?

Explanation. Under the majority's rule, a filing is successive only if it contains a habeas "claim," meaning an asserted federal basis for relief from the state conviction. A Rule 60(b) motion is not successive when it challenges only a defect in the integrity of the federal habeas proceeding, such as a statute-of-limitations ruling that precluded a merits determination. Luis attacks only that procedural barrier, so the motion is not second or successive. (Derived from Gonzalez v. Crosby (n.d.).)